Internal Revenue Service

Internal Revenue Service PO Box 630 Holtsville, NY 11742-0630 Stop 632-I Di1e: APR 2 5 2017 Leon D & Debra Black C/O Elysium 445 Park Ave Apt 1401 New York, NY 10022-0000 Department of the Treasury Taxpayer Identification Number: [SSN REDACTED] Tax Form: 1040 Tax Periodis): 2012 Person to Contact: M. Mclaurin Employee Identification Number: 0178207440 Contact Telephone Number: 631.447-4831 Fax 1-(855) 241-0441 Refer to: Interest Computation Schedule Dear Leon D & Debra Black: As required by Internal Revenue Code Section 6631, we are providing a copy of the schedule we used to calculate interest on the tax adjustment for the return identified above. This computation is for your information. The enclosed Interest Computation Schedule is not a bill for tax due. We will either scnd you a bill within the next few weeks or send you a statement of any refund. If you have any questions, please contact the person named above within 45 days from the date of this letter. Sincerely yours, L ett ifyytaila) Mariellen Fiedler Exam Field Support Operation Manager Enclosure: Interest Computation Schedule Letter 3535 (3.2002) Catalog Number: 33709U EFTA00598897 490 Activity Summary - LEON D & DEBRA BLACK FED - • *•-"-1069 LEON D& DEBRA BLACK 1040 Tax Period: 2012/12 Run Method: Interest To: GATT Method: I.CU Method: Underpay Net Sian: IRS Default 05/05/2017 N/A N/A All Dates Included Module Status: Open/(Open) GATT Date: Gait is OFF LCU Interest Date: LCU Interest is OFF Overpay Net Start: All Dates Included Date Transcript Date Date Start Adj / End Description Susp/Equai Principal Balance 12/02/2013 04/15/2013 150 Return Filed & Assessed Tax Liability 71,021,194.00 71,021,194.00 04/15/2013 806 Credit for Withheld Taxes and Excess FICA (36,822.00) 70,984,372.00 Various 04/15/2013 660 Estimated Tax (24,000,000.00) 46,984,372.00 04/15/2013 670 Subsequent Payment (46,000,000.00) 984.372.00 04/15/2012 04/15/2013 710 Overpayment Credit Applied from Prior Tax IN (10,156,317.85) (9,171,945.85) 04/15/2013 826 Overpayment Transferred 12,858.38 (9,159,087.47) 04/15/2013 830 Overpayment Credit Elect to Next Periods Tax 9,159,087.47 0.00 05/05/2017 04/15/2013 300 Additional Tax Assessment By Examination D 315,590.00 315,590.00 Date Description Amount Factor Inlerc•1 Balance 04/15/2013 04/16/2013 05/05/2017 ISO Return Filed & Assessed Tax Liability 300 Additional Tax Assessment By Examination 660 Estimated Tax 670 Subsequent Payment 710 Overpayment Credit Applied from Prior Tax 806 Credit for Withheld Taxes and Excess FICA 826 Overpayment Transferred 830 Overpayment Credit Elect to Next Periods T: Underpay 71,021,194.00 315,590.00 (24,000,000.00) (46,000,000.00) (10,156,317.85) (36.822.00) 12,858.38 9,159,087.47 315,590.00 0.141765915 44,739.91 315,590.00 360,329.91 Account Summary: Deficiency Interest Overpayment Interest Principal Balance As Computed Per Transcript Adjustment 44,739.91 44,739.91 315,590.00 44.739.91 360,329.91 Copyright O 2002-2017 Decision Modeling. Inc. InterestMet 7.1.6 04/24/2017 10:09 PO Par, 1 OF EFTA00598898 510 Support of Revised Comps - LEON D & DEBRA BLACK FED - •••!•-1069 LEON D & DEBRA BLACK 1040 Tax Period: 2012112 Run Method: Interest to: GATT Method: LCU Method: Underpay Net Stan: IRS DefhWt 05/05/2017 N/A NIA All Dates Included Module Status: Opent(Open) GATT Date: Gall is OFF LCU Interest Dale: LCU Interest is OFF Overpay Net Stan: All Dates Included New Activity for 04/15/2013 Note New Event Equalize Susp Over 150 300 Return Filed 6 Assessed Tax Liability Addreonal Tax Assessment By Examinabon Division 71.021.194.00 315,59000 660 Estimated Tax (6,000000 00) 660 Estimated Tax (4,000.000 00) 660 Estimated Tax (14.000.000 00) 670 Subsequent Payment (46.000.000 00) 710 Overpayment Crecbt Applied from Pnor (10.156.317.85) Tax Period 806 Credit for Withheld Taxes and Excess (36.822 00) FICA 826 Overpayment Transferred 12,85838 830 Overpayment Croat Elect to Next 3.159.087.47 Periods Tax Date Total/ Susp. Balance 914590.00 Interest Computations 04/16/2013 - 05/0512017 New Susp Applied Balance 4/1 5/2013 Intermit Balance Sum Under New Closing Rate Interest Balance Principal Underpay 315.590.00 315.590 AD Under 54,739.91 315,590 00 Interest Underpay 44.739 91 Subtotal Post New Interest 315,590.00 115,590.00 44,739.91 160.129 91 Copyright 0 1999.2017 Decision modeling. Inc. DM1 InterestNet. 7.1.6 04/24/2017 10:09 AM PAGE 1 OF 1 EFTA00598899 Department of the Treasury Internal Revenue Service Leon D & Debra Black C/O Elysuim 445 Park Ave Apt 1401 New York NY 10022-0000 EFTA00598900 Internal Revenue Service Department of the Treasury Post Office Box 630 Stop 632-1 Holtsville, NY 11742-0630 Leon D & Debra Black C/O Elysium 445 Park Ave Apt 1401 New York, NY 10022-0000 Dear Leon D & Debra Black: Date: APR 2 5 2017 Taxpayer Identification Number: [SSN REDACTED] Name of Partnership: Please see Form 4549A for this information Partnership ID Number. Please see Form 4549A for this information Tax Year Ending: December 31, 2012 Person to Contact: M. Mclaurin Employee Identification Number 0178207440 Contact Hours: 8:00am-2:30pm EST Mon-Fri Telephone Numbers: (631)-447-4831 Fax 1-(855) 241-0441 (Not a toll-free number) Notice of Computational Adjustment We have completed our examination of the partnership return for the year(s) shown above. The enclosed Form 4549-A, Income Tax Discrepancy Adjustments, explains changes made to your income tax liability, including applicable penalties, as a result of our examination of the partnership. Form 4549-A does not require any signatures, should not be returned to us, and should be kept for your records. The adjustments are being made as a result of: • an agreement you signed, • an agreement signed by representatives of an entity you are directly or indirectly invested in, • a court decision. • an Administrative Adjustment Request, • allowing a Notice of Final Partnership Administrative Adjustment that was sent to you, the Tax Matters Partner of the partnership or an entity through which you hold your partnership interest, to lapse without bringing a timely challenge in Tax Court, or • failure to file consistently with the partnership return. This notice of computational adjustment includes a Form 4549-A which reflects the amount you owe based upon adjustments to a partnership(s) in which are directly or indirectly invested. This does not include any adjustments that may be proposed as a result of any other partnership examinations not referenced above. You may choose to pay the amount shown on the Form 4549-A, as interest will continue to accrue on any unpaid balance. You will receive a separate billing that will reflect any credits/payments and updated interest calculations. If you are due a refund, it will be issued to you if you owe no other taxes, have no other legal obligations that we are required to collect, and are not a party to any other partnership examinations. If you are due a refund, it should be sent to you within six to eight weeks. Letter 4735 (11-2011) Catalog Number 57922V EFTA00598901 To dispute the computational adjustment made to your return or to assert partner-level defenses to any penalty imposed in this notice, you must pay the tax as adjusted in full, and then file a claim for refund at the address provided above within six months from the date of this letter. If you send your claim to an address other than the above address, processing will be delayed and your claim may be disallowed if received at the address specified in this letter after the end of the six-month period. You may file a refund suit as provided by law if your timely-filed refund claim is disallowed or not acted upon within six months after the date it is filed. If you believe that the calculation of the computational adjustment is wrong because of a mathematical error, please contact us. You do not have to pay the tax in order to discuss issues related to the calculation of the liability. You may call the person whose telephone number and contact hours are shown above or write that person at the IRS address at the top of this letter. Additionally, if you have any other questions about this notice, contact the person listed on this form as they will be most familiar with your case. If you do not contact us concerning any mathematical errors related to this liability within six months from the date of this letter, your failure to contact us may preclude you from raising these issues during any later collection due process proceedings. If you have any affected items subject to deficiency procedures, a separate notice of deficiency will be sent to you. If you write, please include your telephone number, the hours you can be reached and a copy of this letter. Thank you for your cooperation. t Sincerely, ertate-ate3 Lep?) Mariellen Fiedler Exam Field Support Operation Manager Enclosures: Form 4549-A Copy of this letter Letter 4735 (11-2011) Catalog Number 57922V EFTA00598902 Internal Revenue Service Post Office Box 630 Stop 632-1 Holtsville, NY 11742-0630 Leon D & Debra Black C/O Elysium 445 Park Ave Apt 1401 New York, NY 10022-0000 Dear Leon D & Debra Black: Department of the Treasury Date: APR 2 5 2011 Taxpayer Identification Number: [SSN REDACTED] Name of Partnership: Please see Form 4549A for this information Partnership ID Number. Please see Form 4549A for this information Tax Year Ending: December 31. 2012 Person to Contact: M. Mclaurin Employee Identification Number: 0178207440 Contact Hours: 8:O0am-2:30pm EST Mon-Fri Telephone Numbers: (631)447-4831 Fax 1-(855) 241.0441 (Not a toll-free number) Notice of Computational Adjustment We have completed our examination of the partnership return for the year(s) shown above. The enclosed Form 4549-A. Income Tax Discrepancy Adjustments, explains changes made to your income tax liability, including applicable penalties, as a result of our examination of the partnership. Form 4549-A does not require any signatures, should not be returned to us, and should be kept for your records. The adjustments are being made as a result of: • an agreement you signed, • an agreement signed by representatives of an entity you are directly or indirectly invested in, • a court decision, • an Administrative Adjustment Request, • allowing a Notice of Final Partnership Administrative Adjustment that was sent to you, the Tax Matters Partner of the partnership or an entity through which you hold your partnership interest, to lapse without bringing a timely challenge in Tax Court, or • failure to file consistently with the partnership return. This notice of computational adjustment includes a Form 4549-A which reflects the amount you owe based upon adjustments to a partnership(s) in which are directly or indirectly invested. This does not include any adjustments that may be proposed as a result of any other partnership examinations not referenced above. You may choose to pay the amount shown on the Form 4549-A, as interest will continue to accrue on any unpaid balance. You will receive a separate billing that will reflect any credits/payments and updated interest calculations. If you are due a refund, it will be issued to you if you owe no other taxes, have no other legal obligations that we are required to collect, and are not a party to any other partnership examinations. If you are due a refund, it should be sent to you within six to eight weeks. Letter 4735 (11-2011) Catalog Number 57922V EFTA00598903 To dispute the computational adjustment made to your return or to assert partner-level defenses to any penalty imposed in this notice, you must pay the tax as adjusted in full, and then file a claim for refund at the address provided above within six months from the date of this letter. If you send your claim to an address other than the above address, processing will be delayed and your claim may be disallowed if received at the address specified in this letter after the end of the six-month period. You may file a refund suit as provided by law if your timely-filed refund claim is disallowed or not acted upon within six months after the date it is filed. If you believe that the calculation of the computational adjustment is wrong because of a mathematical error, please contact us. You do not have to pay the tax in order to discuss issues related to the calculation of the liability. You may call the person whose telephone number and contact hours are shown above or write that person at the IRS address at the top of this letter. Additionally, if you have any other questions about this notice, contact the person listed on this form as they will be most familiar with your case. If you do not contact us concerning any mathematical errors related to this liability within six months from the date of this letter, your failure to contact us may preclude you from raising these issues during any later collection due process proceedings. If you have any affected items subject to deficiency procedures, a separate notice of deficiency will be sent to you. If you write, please include your telephone number, the hours you can be reached and a copy of this letter. Thank you for your cooperation. / Sincerely, Make:bat) Lea) Mariellen Fiedler Exam Field Support Operation Manager Enclosures: Form 4549-A Copy of this letter Letter 4735 (11-2011) Catalog Number 57922V EFTA00598904 Form 4549-A (Rev. Mardi 2013) Department of the Treasury-Internal Revenue Service Income Tax Examination Changes (Unagreed and Excepted Agreed) Pap 1 of 2 Name and Address o Taxpayer Leon D & Debra Black Taxpayer Identification Number 056-38-1069 Return Form No.: 1040 C(O Blysuim Person with whom Name and Title: 44 5 Park Ave Apt 1401 New York NY 10022-0000 examination drenges were discussed. Lece045044braBlaa 1. Adjustments to Income Period End 12/31/2012 Period End Period End a. Ordinary Income 98-0541994 884,006.00 P. Itemized Deductions 17,680.00 C. d. e. I. 9. h. i. I. k. I. m. n. o. P. 2. Total Adjustments 901,686.00 3. Taxable Income Per Return or as Previously Adjusted 378,805,695.00 4. CorrectedTaxablelncome 379,707,381.00 Tax Method SCHEDULE D Filing Status Joint 5. Tax 73,510,289.00 6. Additional Taxes f Alternative Minimum 7. Corrected Tax Liability 73,510,209.00 8. Less a. Foreign Tax Credit 2.099.898.00 Credits b. General Business Credit 57,310.00 e. Prior Year Minimum Tax Credit d. 25,255.00 9. Balance (Line 7 less total of Lines 8a Inn, itd) 71,327,026.00 10. Plus Other Taxes a. Self Employment Tax b. e. d. 8,958.00 11. Total Corrected Tax Liability (Line 9 plus lines 10a thru 10d) 71,336,784.00 12. Total Tax Shown on Return or as Previously Adjusted 71,021,194.00 13. Adjustments to: a. b. c. 14. Deficiency-Increase in Tax or (Overassessmenf - Decrease in Tax) (Line ff fess Line 12 adjusted 1 by Lines 13a through 13c) 315,590.00 15. Adjustments to Prepayment Credits-Increase (Decrease) is. Balance Duo or (Overpayment) • (Line 14 adjusted by Line 15) (Excluding interest and penalties) 315,590.00 Catalog Number 23110T vowtirs.gov Form 4549-A (Rev. 3-2013) EFTA00598905 Form 4549 -A (Rev. Mardi 2013) Department of the Treasury-Internal Revenue Service Income Tax Examination Changes (Unatirced and Excepted Agreed) pa page of 7 Name of Taidaym Leon D & De sellebra Slack C/0 Mo Taxpayer Identification Number 056- 38- 1069 Return Form No.: 1040 17. Penalties/ Code Sections Prod End 12/31/2012 Period End Prod End a. b. C. cl. e. 1. B h. I. k. I. m. n. 18. Total Penalties Underpayment attributable to negligence: (1981.1987) A fax addition of 50 percent of the interest due on the underpayment will accrue until it is paid or assessed. Underpayment attributable to fraud: (1981-1987) A tax addition of 50 percent of the interest due on the underpayment will acme until it is paid or assessed. Underpayment attributable to Tax Motivated Transactions (TMT). Interest win accrue and be assessed at 120% of underpayment rate ai accordance with IRC 6621(c). 0.00 19. Summary of Taxes, Penalties and Interest a. Balance due or (Overpayment)-Taxes - (Line 76, Page 1) b. Penalties (Line 18) - computed to 05/01/2017 C Interest (IRC§ 6601) - computed to 05/31/2017 d. TMT Interest- computed to 05/31/2017 (on TMT underpayment) e. Amount due or refund - (sum el Lines a, ti, c and di 315,590.00 0.00 0.00 3:5.590.00 Other Information: We have adjusted your return in accordance with the examination results for the identified BRH Holdings LP 98.0541994 partnership. The examination results aro based on the Notice of Final Partnership Administrative Adjustment and the Schedule of Adjusted Items, which were not petitioned during the statutory period. If you have any questions, please contact your Tax Matter Partner. Examiner's Signature: Name M. Mclaurin Employee ID: 0 1 7 8 2 0 7 4 4 0 Office: BSC 631-447-4831 Date 05/01/2017 The Internal Revenue Service has agreements with sta e tax agencies under which information about federal tax. including increases or decreases, is exchanged with the states. If this change affects the amount of your slate income tax, you should amend your state return by filing the necessary forms. You may be subject to backup withholding if you underreport your interest, dividend. or patronage dividend income you earned and do not pay the required tax. The IRS may order backup withholding (withholding of a percentage of your dividend andror interest payments) if the tax remains unpaid after it has been assessed and four notices have been issued to you over a 120-day pinned. Catalog Number 23110T www.irs.gov Form 4549-A (Rev. 3-2013) EFTA00598906 Name of Taxpayer: Leon D & Debra Black 05/01/2017 Identification Number: 056.38.1069 Total 18.00.00 2012 - Form 3800 - General Business Credit Part I - Current Year Credit for Credits Not Allowed Against Tentative Minimum Tax (TMT) 1. General business credit from a non-passive activity 2.General business credit allowed from a passive activity 3. General business credit carryforwards 4. General business credit carrybacks 5. Tentative general business credit (sum of lines 1 through 4) Part II - Allowable Credit 6. Regular tax before credits 7. Alternative minimum tax 8. Total of lines 6 and 7 9. Foreign tax credit 10.Allowable separately stated credits 11.Total of lines 9 through 10 12.Net income tax (line 8 less line11) 13.Net regular tax (line 6 less line 11) 14 If line 13 is more than $25,000, enter 25% of the excess 15.Tentative minimum tax 16.Greater of line 14 or line 15 17.Line 12 less line 16 (if zero or less, enter -0-) 18.Bonus depreciation amount 19.Add lines 17 and 18 20.Smaller of Part I, line 5 above or Part II, line 19 21.Smaller of Part I, line 5 above or Part II, line 17 22.Subtract line 21 from line 20 Skip lines 23 through 27 and enter -0- on line 28 if there is no tentative empowerment zone and renewal community employment credit 23.Multiply line 15 by 75% 24.Greater of line 14 or line 23 25.Subtract line 24 from line 12 (if zero or less, enter -0-) 26.Subtract line 21 from line 25 (if zero or less, enter -0-) 27.Tentative empowerment zone and renewal community employment credit 28.Empowerment zone and renewal community employment credit allowed (smaller of line 26 or line 27) 29.Subtract line 14 from line 12 (if zero or less, enter -0-) 30.Add lines 21 and 28 31.Subtract line 30 from line 29 (if zero or less, enter -0-) 32.Business credit from a non-passive activity 33.Eligible small business credit from a non-passive activity 34.Business & eligible small business credit allowed from a passive activity 35.Business & eligible small business credit carryforwards 36.Business & eligible small business credit carrybacks 37.Tentative business and eligible small business credit (sum of lines 32 through 36) 38.Smaller of line 31 or line 37 39.Current year credit allowed (add lines 30 and 38) 1,075.00 0.00 56,235.00 0.00 57,310.00 73,510,289.00 0.00 73.510.289.00 2,099,898.00 0.00 2,099,898.00 71,410,391.00 71,410,391.00 17.846.347.75 69,138,526.00 69,138.526.00 2,271,865.00 0.00 2.271,865.00 57,310.00 57,310.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 53,564,043.25 57,310.00 53,506,733.25 0.00 0.00 0.00 0.00 0.00 0.00 0.00 57,310.00 EFTA00598907 Name of Taxpayer: Leon D & Debra Black 05/0112017 Identification Number: [SSN REDACTED] Total 18.00.00 2012 • Form 6251 - Alternative Minimum Tax Computation 1. If filing Schedule A. enter taxable income before exemptions: otherwise, enter adjusted gross income 2. Total adjustment and preferences (excluding any NOL deduction) 3. Net operating loss deduction 4. Alternative tax net operating loss deduction 5. Alternative minimum taxable income (combine lines 1 thru 4) 6. Exemption amount 7. Subtract line 6 from line 5 (if zero or less, enter zero) 8. If capital gains are reported, see line 19 from continuation page (If REIT worksheet for AMT is used, enter amount from line 6 of that worksheet instead) All others: If line 7 is $175,000 or less ($87,500 if MFS) multiply line 7 by 26%. Otherwise, multiply line 7 by 28% and subtract $3,500 ($1,750 if MFS) from the result 9. Alternative minimum tax foreign tax credit 10. Tentative minimum tax (line 8 less line 9) 11. Regular tax before credits (if Schedule J was used to figure tax, use the refigured amounts for lines 44 and 47 of Form 1040 without using Schedule J) 12. Alternative minimum tax Exemption Worksheet (line 6 above) A. Exemption amount based on filing status B. Alternative minimum taxable income C. Enter $112,500 ($150,000 if married filing jointly or qualifying widow(er), $75,000 if married filing separately) D. Subtract line C from line B E. Multiply line D by 25% F. Subtract line E from line A (if zero or less, enter zero) 379,722,581.00 11,432,719.00 0.00 0.00 391,155,300.00 0.00 391.155.300.00 70.966.420.00 1,827,894.00 69,138,526.00 71,410,391.00 0.00 78,750.00 391.155.300.00 150,000.00 391,005,300.00 97,751,325.00 0.00 EFTA00598908 Name of Taxpayer: Leon D & Debra Black 05/01/2017 Identification Number: [SSN REDACTED] Total 18.00.00 2012 - Form 6251 - Continuation, Tax Computation Using Maximum Capital Galn 1. Amount from Form 6251 report, line 7 (If FEIT worksheet for AMT was used, enter amount from line 3 of that worksheet instead) 2. Amount from line 6 Qualified Dividends and Capital Gain Tax Worksheet or line 13 Schedule D Tax Worksheet (refigured for AMT) 3. Amount from Schedule D line 19 (refigured for AMT) 4. Amount from line 2 if no Schedule D worksheet; otherwise, the smaller of the sum of line 2 and line 3 or Schedule D worksheet line 10 (refigured for AMT) 5. Smaller of line 1 or line 4 6. Subtract line 5 from line 1 7. If line 6 is $175,000 or less ($87,500 if MFS) multiply line 6 by 26%; otherwise, multiply line 6 by 28% and subtract $3,500 ($1,750 if MFS) from the result 8. Enter: $70,700 if married filing jointly or qualifying widow(er) $35,350 if single or married filing separately $47,350 if head of household 9. Amount from line 7 Qualified Dividends and Capital Gain Tax Worksheet or line 14 Schedule D Tax Worksheet 10. Subtract line 9 from line 8 (if zero or less, enter zero) 11. Smaller of line 1 or line 2 12. Smaller of line 10 or line 11 13. Subtract line 12 from line 11 14. Multiply line 13 by 15% 15. Subtract line 11 from line 5 16. Multiply line 15 by 25% 17. Total of lines 7, 14 and 16 18. If line 1 is $175,000 or less ($87,500 if MFS) multiply line 1 by 26%; otherwise, multiply line 1 by 28% and subtract $3,500 ($1,750 if MFS) from the result 19. Smaller of line 17 or line 18. Enter here and on line 8 of Form 6251 report Rates 391,155,300.00 296,380,486.00 803,368.00 297,183,854.00 297,183,854.00 93,971,446.00 26,308,505.00 70,700.00 83,326,895.00 0.00 296,380,486.00 0.00 296,380,486.00 44,457,073.00 803,368.00 200,842.00 70,966,420.00 109,519,984.00 70,966,420.00 EFTA00598909 Name of Taxpayer: Leon D 8 Debra Stack 05/01/2017 Identification Number: [SSN REDACTED] Total 18.00.00 2012 - Form 8801 - Credit for Prior Year Minimum Tax Part I - Net Minimum Tax on Exclusion Items 1. Taxable income (loss) from prior year Form 6251 2. Adjustments and preferences treated as exclusion items 3. Minimum tax credit net operating loss deduction 4. Combine lines 1 through 3 (if more than 5223900 and married filing separate for prior year - see instructions) 5. Exemption amount from prior year Form 6251 6. Phaseout exemption from prior year Form 6251 7. Subtract line 6 from line 4 (if zero or less, enter -0-) 8. Multiply line 7 by 25% 9. Subtract line 8 from line 5 (if zero or less. enter -0-) 10. Subtract line 9 from line 4 (if zero or less. enter -0-) 11. Une 11 computation (d filing Form 2555/2555•E2 for prior year, enter amount from page 3) or, (if capital gains for prior year. enter amount from Pan Ill, line 47): otherwise. multiply line 10 by 28% and subtract $ 3,500 from the result) 12. Minimum tax foreign tax credit on exclusion items 13. Tentative minimum lax on exclusion items (line 11 Ins line 12) 14. Regular tax before credits minus foreign tax credit (line 34 of prior year Form 6251) 15. Net minimum tax on exclusion items (line 13 less line 14) Part II - Current Year Nonrefundable and Refundable Credits and Carryover 16. Une 35 of prior year Form 6251 17. Amount from line 15 above 18. Adjusted net minimum tax (line 16 less tine 17) 19. Carryforward of minimum tax credit from prior year 20. Prior year unallowed qualified electric vehicle credit 21. Combine lines 18 through 20 22. Current year regular income tax less allowable credits 23. Current year tentative minimum tax (line 33 of Form 6251) 24. Subtract line 23 from line 22 (if zero or less, enter -0-) 25. Current year nonrefundable credit (smaller of fine 21 or line 24) 26. Tentative refundable credit (amount from Pail IV, line 53 or 57) (If applicable) 27. Current year refundable credit (line 26 less line 25) 28. Credit carryforward (subtract larger of line 25 or line 26 from line 21) 93.723.040.00 29.011.633.00 0.00 122,734,673.00 74,450.00 150,000.00 122.584.673.00 30.646.168.00 0.00 122,734,673.00 22.445.889.00 122,464.00 22.323.425 00 14,310,267.00 8,013,158.00 8,008225.03 8,013,158.00 (4,933.00) 30,188.00 0.00 25,255.00 71,353.081 00 61138,526.00 2,214,555.00 25,255.00 12,628 00 0.00 0.00 EFTA00598910 Name of Taxpayer Leon D 8 Debra Black 05/01/2017 Identification Number: 056.38.1069 Total 18.00.00 Part III - Tax Computation Using Maximum Capital Gains Rates 29. Amount from line 10 (If FEIT worksheet for F8801 was used, enter amount from line 3 of that worksheet instead) 30. Amount from prior year line 6 of Qualified Dividends Worksheet or line 13 of Schedule D Tax Worksheet 31. Amount from prior year Schedule D. line 19 32. Smaller of lines 30 and 31 or prior year line 10 of Schedule D Tax Worksheet 33. Smaller of line 29 or line 32 34. Subtract line 33 from line 29 35. Multiply line 34 by 28% and subtract $ 3.500 from the result 36. Enter: 569.000 if married filing jointly or qualifying vAiow(er) for 2011. 534,500 if single or married filing separately for 2011. 546.250 if head of household for 2011 37. Amount from prior year line 7 of Qualified Dividends Worksheet or line 14 of Schedule D Tax Worksheet 38. Subtract line 37 from line 36. If zero or less, enter -0- 39. Smaller of line 29 or line 30 40. Smaller of lino 38 or line 39 41. Subtract Ube 40 from line 39 42. Multiply line 41 by 15% 43. Subtract line 39 from line 33 44. Multiply line 43 by 25% 45. Add lines 35.42. and 44 46. Multiply line 29 by 28% and subtract S 3,500 from the result 47. Smaller of line 45 or line 46 (enter here and on tine 11 above) (If FEIT worksheet for F8801 was used, enter amount on line 4 of that worksheet instead) Part IV - Tentative Refundable Credit 122.734.673.00 91,640,796.00 100.524.00 91,741,320.00 91.741.320.00 30,993,353.00 8,674,639.00 69,000.00 2.067.444.00 0.00 91,640,796.00 0.00 91,640,796.00 13,746,119.00 100,524.00 25,131.00 22,445,889.00 34,362,208.00 22,445,889.00 48. Enter amount from line 21 25,255,00 49. Minimum tax credit amount from 2010 Form 8801, lines 18 and 20 (if zero or less, enter -0-) 0.00 50. Minimum tax credit amount from 2011 Form 8801, lines 18 and 20 (if zero or less, enter -0-) 0.00 51.Total of lines 18 and 20 above (if zero or less. enter -0-) 0.00 52. Add lines 49 than 51 0.00 53. Long-term unused minimum lax credit (subtract line 52 from line 48) (if zero or less, slop and enter -0- here and on line 28 and do not complete the rest of Part IV). 25,25900 54. Multiply line 53 by 50% 12,62900 55. Prior year AMT refundable credit amount 0.00 56. Larger of line 54 or line 55 12,628.00 12,628.00 57. Smaller of line 53 or line 56. Enter result here and on line 26 EFTA00598911 Name of Taxpayer: Leon D & Debra Black 05/01/2017 Identification Number: [SSN REDACTED] Total 18.00.00 2012 - FOREIGN EARNED INCOME TAX WORKSHEET for PRIOR YEAR MINIMUM TAX 1. Enter amount from Form 8801. line 10 2. Enter amount from 2011 Form 2555, line 45 and 50, or Form 2555-EZ, line 18 3. Add lines 1 and 2 4. Tax on amount on line 3 If capital gains are reported for prior year. enter amount from line 3 on Form 8801, line 29. Complete Form 8801, Part Ill and enter amount from line 47 here All others: If line 3 is $175,000 or less ($87,500 or less if married filing separately for prior year). multiply line 3 by 26%: otherwise, multiply line 3 by 28% and subtract $3&00 (51.750 if married filing separately for prior year) from the result 5. Tax on amount on line 2 If line 2 is $175,000 or less ($87,500 or less if married filing separately for prior year). multiply line 2 by 26%: otherwise, multiply line 2 by 28% and subtract 53,500 ($1,750 if married filing separately for prior year) from the result 6. Subtract line 5 from line 4. If zero or less. enter -0- (enter amount here and on line 11 of page 1) NOTE: Computations include capital gain excess determination and any necessary modifications to Form 8801. Part III 0 00 0 00 0.00 0.00 000 EFTA00598912 Name of Taxpayer: Leon D & Debra Black 05/01/2017 Identification Number 056-38-1069 Total 18.00.00 2012 - SCHEDULE A - ITEMIZED DEDUCTIONS PER RETURN PER EXAM ADJUSTMENT 1. Medical, dental and insurance premiums 0.00 0.00 0.00 2. 7.5% of adjusted gross income 30,778.498.00 30.844.797.98 3. Net medical and dental expenses 0.00 0.00 0.00 4. Taxes 6.485.310.00 6.485.310.00 0.00 5. Home interest expense 19,832.00 19.832.00 0.00 6. Qualified mortgage insurance premiums 0.00 0.00 0.00 7. Investment interest 8,029,812.00 8.029.812.00 0.00 8. Other interest expense 0.00 0.00 0.00 9. Total interest expense 8.049.644.00 8.049.644.00 0.00 10. Contributions 12.783.116.00 12.783.116.00 0.00 11. Casualty and theft losses 0.00 0.00 0.00 12. Miscellaneous deductions 12.448.601.00 12.448.601.00 0.00 13. 2% of adjusted gross income 8.207.599.00 8.225.279.00 14. Excess miscellaneous deductions 4.241.002.00 4.223.322.00 17,680.00 15. Other miscellaneous deductions 0.00 0.00 0.00 16. Total itemized deductions (Sum of lines 3, 4, 9, 10, 11, 14, and 15) 31.559.072.00 31.541.392.00 17,680.00 EFTA00598913 Name of Taxpayer: Leon D & Debra Black Identification Number: [SSN REDACTED] Total 05101,2017 18.00.00 2012 - SCHEDULE D - CAPITAL GAINS AND LOSSES Part I Short-Term Capital Gains and Losses—Assets Held One Year or Less 1 Short-term capital gain or loss 3,796,929.00 2 Short-term capital loss carryover 0.00 3 Net Short-tern Gain or Loss (Add line 1 and 2) 3,796,929.00 Part II Long-Term Capital Gains and Losses—Assets Held More Than One Year 4 Long-term capital gain or loss 272,640,171.00 6 Long-term capital gain or loss carryover 0.00 6 Net long-term Gain or Loss (Add line 4 and 5) 272,640,171.00 Part III Summary 7 Sum of lines 3 and 6 - Net Capital Gain or Loss 276,437,100.00 8 Capital loss limitation 0.00 9 Capital Gain or Loss-As Corrected 276,437,100.00 10 Capital Gain or Loss - Per Return 276,437,100.00 11 Line 9 less line 10 - Adjustment to Income 0.00 CORRECTED CARRYOVER 12 Short-term Carryover to Subsequent Year 0.00 13 Long-term Carryover to Subsequent Year 0.00 28% RATE GAIN COMPUTATION 1 Tentative 28% rate gain (total of lines 1 thru 4 from worksheet) 0.00 2 Long-term capital loss carryover 0.00 3 Net short-term capital loss 0.00 4 Allowable 28% rate gain (sum of lines 1 thru 3) (if -0- or less, enter -0-) 0.00 SECTION 1250 GAIN COMPUTATION 1 Tentative Section 1250 gain (line 13 from worksheet) 803,368.00 2 Tentative 28% rate gain 0.00 3 Net short-term capital loss 0.00 4 Long-term capital loss carryover 0.00 5 Sum of lines 2 thru 4 (if less than -0-, enter as positive amount) (if -0- or greater, enter -0-) 0.00 6 Allowable Section 1250 gain (line 1 less line 5) (if -0- or less, enter -0-) 803,368.00 EFTA00598914 Name of Taxpayer: Leon D & Debra Black 05/01/2017 Identification Number: [SSN REDACTED] Total 18.00.00 2012 - Schedule D Tax Worksheet 1. Enter the taxable income from Form 1040. line 43. or the amount from Foreign Earned Income Tax Worksheet, line 3, it filing Form 2555 or 2555-EZ 379.707,381.00 2. Enter the qualified dividends from Form 1040, line 9b 24,543,683.00 3. Enter the amount from Form 4952, line 4g 0.00 4. Enter the amount from Form 4952, line 4e 261,989,805.00 If applicable, enter the smaller of line 4e or the amount on the dotted line next to line 4e of Form 4952 5. Subtract line 4 from line 3. If zero or less, enter -0- 0.00 6. Subtract line 5 from line 2. If zero or less. enter -0- 24,543483.00 7. Enter the smaller of line 15 or line 16 of Schedule D 272,640,171.00 8. Enter the smaller of line 3 or line 4 0.00 9. Subtract line 8 from line 7. If zero or less, enter -0- 272.640.1711.00 10. Add lines 6 and 9 297.183.854.00 11. Add lines 18 and 19 of Schedule D 803,368.00 12. Enter the smaller of line 9 or line 11 803,368.00 13. Subtract line 12 from fine 10 296,380,486.00 14. Subtract line 13 from line 1. If zero or less, enter -0- 83.326.895.00 15. Enter: $35,350 it single or married filing separately: $70,700 if married filing jointly or qualifying widow(er): or $47,350 if head of household 70,700.00 16. Enter the smaller of line 1 or line 15 70,700.00 17. Enter the smaller of line 14 or line 16 70.700.00 18. Subtract line 10 from line 1. If zero or less, enter -0- 82.523.527.00 19. Enter the larger of line 17 or line 18 82.523527.00 20. Subtract line 17 from line 16. This amount is taxed at 0% 0.00 If lines 1 and 16 are the same, skip lines 21 through 33 and go to line 34. Otherwise, go to line 21. 21. Enter the smaller of line 1 or line 13 296.380.486.00 22. Enter the amount from line 20 (if line 20 is blank, enter -0-) 0.00 23. Subtract line 22 from line 21. If zero or less, enter -0- 296.380.486.00 24. Multiply line 23 by 15% (.15) 44,457,073.00 If Schedule 0, line 19, is zero or blank, skip lines 25 through 30 and go to line 31. Otherwise. go to line 25. 26. Enter the smaller of line 9 above or Schedule D. line 19 903.368.00 26. Add lines 10 and 19 379,707,381.00 27. Enter the amount from line 1 above 379.707.381.00 28. Subtract line 27 from line 26. If zero or less, enter -0- 0.00 29. Subtract line 28 from line 25. If zero or less, enter -0- 803,368.00 30. Multiply line 29 by 25% (.25) 200,842.00 If Schedule D. line 18, is zero or blank, flip lines 31 through 33 and go to line 34. Otherwise, go to line 31. 31. Add lines 19. 20, 23, and 29 32. Subtract line 31 from line 1 33. Mukiply line 32 by 28% (.28) 34. Figure the tax on the amount on line 19. If the amount on line 19 is less than $100,000. use the Tax Table to figure the tax. If the amount on line 19 is $100,000 or more. use the Tax Computation Worksheet 28.852.374.00 35. Add lines 24, 30. 33, and 34 73,510289.00 36. Figure the tax on the amount on line 1. If the amount on line 1 is less than 4100000. use the Tax Table to figure the tax. If the amount on line 1 is $100,000 or more, use the Tax Computation Worksheet 132,866.723.00 37. Tax on all taxable income (including capital gains and qualified dividends) Enter the smaller of line 35 or line 36. Also include this amount on Form 1040, line 44, or 73.510.289.00 Foreign Earned Income Tax Worksheet, line 4. if applicable EFTA00598915 Form 886-A (Rev. January 1994O86-A EXPLANATION OF ITEMS Schedule mamba or exhibit Name of Taxpoyer Leon D & Debra Black Taxpayer Identification Number 056-38-1060 Yew/rem:4 Ended 2012 Ordinary Income 98-0641994 Tax Period Per Return 2012 $53,400,301.00 Per Exam Adjustment $54,284,307.00 $884,006.00 We have adjusted your return in accordance with the examination results for the identified BRH Holdings LP 98- 0541994 partnership. The examination results are based on the Notice of Final Partnership Administrative Adjustment and the Schedule of Adjusted Items, which were not petitioned during the statutory period. Statutory-Itemized Deductions Tax Period 2012 Per Return $31,559,072.00 Per Exam Adjustment $31,541,392.00 $17,680.00 Certain expenses deducted as miscellaneous itemized deductions are only deductible to the extent that they exceed a percentage of your adjusted gross income. Since we have made other changes in this report which affect your adjusted gross income, we have also adjusted these expenses. Form 886-A (1-1994) Department of the Tr 6in - Intents! Revenue Sank. EFTA00598916