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

From: "jeffrey E." <[email protected]> To: Melanie Spinella Subject: Fwd: Split Interest Property Purchase Date: Thu, 31 Jul 2014 19:10:21 +0000 tomorows news today Forwarded message From: Ada Clapp <1 Date: Thu, Jul 31, 2014 at 3:03 PM Subject: Split Interest Property Purchase To: "jeffrey E." <[email protected]> Cc: Eileen Alexanderson , "Halperin, Alan S" Hi Jeffrey, Richard is OK with doing the split interest purchase of the townhouse provided that we discuss with Leon (and Leon discusses with Debra) the option of Leon giving Debra the funds to do the split-interest purchase with the trust so that Debra, rather than Leon, would retain the life interest. From Richard's viewpoint, that is a better deal for the Trust because Debra has the longer life expectancy (the trust pays less to purchase the remainder). He thought that would basically put Leon in the same place Debra would be if Leon had the life estate and that Leon should be fine with that. I pointed out to Richard that the positions were not exactly the same. Because Leon is not a beneficiary of the trust, if Debra holds the life interest and he outlives her, he will have to pay rent. In contrast, if Leon holds the life interest and Debra outlives him, the Trustees could allow her to live in the residence rent free. There may also be an issue with Leon being denied a marital deduction for the funds he gives Debra to acquire the life interest (the service may assert the step transaction argument). Alan is looking into this and will also quantify what Debra's contribution would be if she were the sole life tenant. I will get back to you once I have that information. Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: Fax: EFTA00994026 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 EFTA00994027