From: "Barry J. Cohen" <

From: "Barry J. Cohen" < To: jeffrey E. <[email protected]> Subject: Re: Phaidon Date: Wed, 20 Sep 2017 01:11:20 +0000 5-6 EY people have told us that they have experience with audits. I thought I gave you all the names before. I will get you a list of everyone we talk to at every firm who has audit experience! Sent from my iPhone On Sep 19, 2017, at 7:04 PM, jeffrey E. [email protected]> wrote: do they have names 999999I On Tue, Sep 19, 2017 at 5:28 PM, Barry J. Cohen < wrote: Phaidon may be $30MM. You are consumed with audit experience! Some of our tax team (mostly EY) have it. Others less so. Sent from my iPhone On Sep 19, 2017, at 5:09 PM, jeffrey E. [email protected]> wrote: I actually dont care whether or not he agrees . I would ask that you merely inquire as to how many 1040 fed audits 1040 large case or 10 40 wealth squad audits hes actually managed or partcipated in. how much loss do you think you can generate this year with a phaidon transaction.? On Tue, Sep 19, 2017 at 4:29 PM, Barry J. Cohen < > wrote: He is agreeing with you on gift tax returns. Can't leave everything blank. From: Jeffrey E. [mailto:jeevacation@gmail corn] Sent: Tuesday, September 19, 2017 4:25 PM To: BarryJ. Cohen Subject: Re: 000's think about it, again, ask joe how many 1040 audits he has done. . what size. how complex. when we file a grat, we calulate the gift explicity at zero. . it is the calculation of a gift minus the annuity. It is simple math. no more 2 minus ( 1+1) does not equal NONE On Tue, Sep 19, 2017 at 4:19 PM, Barry J. Cohen < > wrote: EFTA00664988 Fair enough. From: Jeffrey E. [mailto:[email protected]] Sent: Tuesday, September 19, 2017 4:19 PM To: Barry J. Cohen < > Subject: Re: 000's dumb' ti iti 1, as i told you, computers dont read letters On Tue, Sep 19, 2017 at 4:15 PM, Barry J. Cohen < wrote: Sorry I misunderstood on the 000s. Gift tax returns have to report a number somewhere, so maybe statute doesn't start. But if you filed an income tax return for an entity with no income or expenses, Joe V assumes the statute would start. In any event, we don't file returns that way. As I said, we would say "None" where appropriate. From: Jeffrey E. [mailto:[email protected] Sent: Tuesday, September 19, 2017 4:09 PM To: Barry J. Cohen •,: > Subject: Re: 000's i did not suggest you use the 000 method. Im sony but i dont have the time . do you think if you filed a gift tax return and left everything blank the statue would run? On Tue, Sep 19, 2017 at 4:03 PM, Barry J. Cohen < > wrote: John Cook at EY said they would not sign a return that uses the 000s method. They said that there are too many footing problems. Numbers won't tie to K-ls, W-2s, I099s, etc. Also, if you only use it on part of the return, the various numbers on the return would not match internally. He also pointed out that this method effectively truncates numbers; though I'm not sure what rounding rules you use. E.g., 101,499 become 101? What happens to the other $499? Joe V likes the idea of putting in 0's instead of blanks. He says he uses "none". He did not understand why this would affect the statute of limitations. Barry J. Cohen I Elysium Management, LLC I 445 Park Avenue Suite 1401 EFTA00664989 New York, NY 10022 I Tel. (646) 589-0322 I Cell 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 [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 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 [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note EFTA00664990 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 and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 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 , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 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 , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00664991