EFTA02708012

From: Ada Clap Sent: Friday, September 20, 2013 9:53 PM To: Jeffrey Epstein Cc: Eileen Alexanderson Subject: Draft Advisory Opinion Attachments: DRAFT-Avisory Opinion Petition (9.20.13).docx; Untitled attachment 00166.htm Hi =effrey, See attached revisions to the draft Petition =uggested by Alan. Alan has the same view I shared with you =arlier (better not to mention grantor trust status and flag Rothstein) =ut noted that if you wish to highlight grantor trust status, the =ttached language is more appropriate. "Irrevocable defective =rantor trust" is merely a term of art used by planners and is not in =he tax code. Have a nice =eekend. c/o Apollo Management 9 W 57th =treet New York NY 10019 phone email: IRS Circular 230 =isclosure: Pursuant to IRS regulations, I inform you =hat any tax advice contained in this communication (including =ttachments) is not intended or written to be used, and cannot be used =y any person or entity for the purpose of (i) avoiding tax related =enalties imposed by any governmental tax authority, or (ii) promoting, =arketing or recommending to another party any transaction or matter =iscussed herein. I advise you to consult with an independent tax =dvisor on your particular tax circumstances. This =ommunication, and any attachment, is for the intended recipient(s) only =nd may contain information that is privileged, confidential and/or =roprietary If you are not the intended recipient, you are hereby =otified that further dissemination of this communication and its =ttachments is prohibited. Please delete all copies of this =ommunication and its attachments and notify me immediately that =ou have received them in error. EFTA_R1_02107424 EFTA02708012