From: "jeffrey E." <[email protected]>

From: "jeffrey E." <[email protected]> To: Melanie Spinella Subject: Fwd: Fair Market Value Deduction Denied for Charitable Contribution Date: Fri, 27 Mar 2015 14:33:18 +0000 Forwarded message From: Ada Clapp -1 Date: Fri, Mar 27, 2015 at 9:50 AM Subject: RE: Fair Market Value Deduction Denied for Charitable Contribution To: "jeffrey E." <frevacation(kgmail.com> Cc: Brad Wechsler >, "Halperin, Alan S" I read the CCA. Discussed it with Brad and we thought it was prudent to ask Alan's view on how it might affect our planning. Alan indicated that he wanted an associate to review the underlying cases and rulings so they could gage its application. We agreed. Once the associate did so, he memorialized his research and I asked that it also provide some guidelines. Ada Clapp Chief Legal Officer Elysium Management LLC Email: This communication and any attachment is for the intended recipient(s) only and may contain information that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemination of this communication and its attachments is prohibited. Please delete all copies of this communication and its attachments and notify me immediately that you have received them in error. Thank you. From: Jeffrey E. [mailto:[email protected] Sent: Friday, March 27, 2015 9:36 AM EFTA00861284 To: Ada Clapp Cc: Brad Wechsler; Heather Gray; Richard Joslin; Halperin, Alan S Subject: Re: Fair Market Value Deduction Denied for Charitable Contribution was this communication initated by us? or are they sending it to all their art clients. ?? On Fri, Mar 27, 2015 at 9:22 AM, Ada Clapp < > wrote: PRIVILEGED AND CONFIDENTIAL -ATTORNEY WORK PRODUCT Attached is a memorandum prepared by Paul Weiss with respect to the recently issued Chief Counsel Advisory 201443019. For your information, the CCA is attached at the back of the memorandum. Ada Clapp Chief Legal Officer Elysium Management LLC Direct Dial: Fax: Email: This communication and any attachment is for the intended recipient(s) only and may contain information that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemination of this communication and its attachments is prohibited. Please delete all copies of this communication and its attachments and notify me immediately that you have received them in error. Thank you. 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 EFTA00861285 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 EFTA00861286