From: "Dlugash, Alan"

From: "Dlugash, Alan" To: jeffrey E. <[email protected]>, Richard Kahn Subject: RE: Avionetta Date: Mon, 14 Sep 2015 03:09:34 +0000 Joslin has asked me to look at some revised depreciation figures as well as to confirm that I agree with Avionetta's overall reporting. Basically, a loss of $900k is being claimed on the 135 flights (ignoring the 91 flights) during the year, on which a "reasonable" hourly rate is being charged. Depreciation is being daimed conservatively, including taking depreciation on the fair market value (instead of cost) since FMV was lower than cost when business use started being claimed. I do agree with the overall approach, and would tell him so (by phone tomorrow afternoon) subject to your OK. I'm looking at the depreciation now, and it so far looks fine. He has also asked me about a grantor trust reporting issue, which looks fine, and on which he already received approval from Paul Weiss (Halperin). I will forward to you momentarily the recent emails on Avionetta and the Grantor trust issues. Alan Alan J. Dlugash Marks Paneth & Shron LLP 685 Third Avenue. New York, NY. 10017 go,Marks, Paneth & Shron From: jeffrey E. [[email protected]] Sent: Sunday, September 13, 2015 6:16 PM To: Richard Kahn; Dlugash, Alan Subject: is there anything that needs to be done for avionetta. ? ? happy new year please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved Any tax advice in this e-mail should be considered in the context of the EFTA00652003 tax services we are providing to you. Preliminary tax advice should not be relied upon and may be insufficient for penalty protection. CONFIDENTIALITY NOTE: This transmission may contain confidential and/or privileged information. This information is intended for use by the individual or entity named above. If you are not the intended recipient, be aware that any disclosures, copying, distribution or use of the contents of this information is prohibited. If you have received this transmission in error, please notify this office immediately. EFTA00652004