From: "Barry J. Cohen"

From: "Barry J. Cohen" To: Jeffrey E. <jeevacationggmail.com> Subject: RE: FW: Plane trips--PRIVILEGED AND CONFIDENTIAL Date: Thu. 10 Aug 2017 18:19:26 +0000 That's how I asked the question. Like you say, virtually no one is exactly like Leon. He briefly discussed a current audit where the agent is disallowing depreciation where it is clearly allowed and no record keeping or explanation of the law seems to help. Some agents just hate the idea of individuals taking deductions on big planes. He said sometimes showing a well-compiled book of extensive trip documentation has been very effective in making the whole trip go away. He acknowledged that sometimes detailed trip purpose logs can give the agent more room to challenge, but on balance better documentation has been a benefit in audit. Glad to get you on the phone with him at some point. From: Jeffrey E. [mailto:[email protected]] Sent: Thursday, August 10, 2017 2:13 PM To: Barry J. Cohen < Subject: Re: FW: Plane trips--PRIVILEGED AND CONFIDENTIAL Big jet PRIVATELY OWNED ? What have they asked On Thu, Aug 10, 2017 at 12:10 PM Barry J. Cohen < The people we talk to are not saying otherwise. Agree with you. From: Jeffrey E. imailto:[email protected]] Sent: Thursday, August 10, 2017 2:08 PM To: BarryJ. Cohen < > Subject: Re: FW: Plane trips--PRIVILEGED AND CONFIDENTIAL wrote: Nonsense - again. These are residency audits predominantly. Ny state wants to tax other state residents or people that claim income is earned elsewhere. Nystate works off of federal . On Thu, Aug 10, 2017 at 11:56 AM Barry J. Cohen < wrote: Here is a plane trip summary. I asked Leon to provide color on art-related use of the plane along with other investment related use or business related use. You were questioning whether we needed that. We've been talking to the EY plane tax guy, who seems very competent. He has been involved in numerous audits involving planes of every size, and has some active audits now. He says that the audits are all over the place on what they like to see in terms of back up. He prefers more back up than less. Regarding audits more generally, I meant to mention that several tax people have advised us that state auditors have been very active, are expected to increase their activity, and often behave completely differently from the VHNW IRS auditors. The IRS has little budget for expansion, but the states are spending money and hiring agents. California, NY and CT are the worst. please note The information contained in this communication is confidential, may be attorney-client privileged, may EFTA00718048 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 jeevacation@gmail com and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00718049