From: J <jeevacation®gmail.com>

From: J <jeevacation®gmail.com> To: Richard Kahn < >, Alan Dlugash Subject: Date: Fri, 05 Oct 2018 13:57:02 +0000 • All of the 8621 numbers are Apollo flow through figures, as reported to us on the BRH K-1 and are properly reported, as income from QEF elected PFICS. • What cost of goods sold numbers are you referring to? All reported costs of goods sold are in the proper places on either schedule C, the 8865 or the 8858s. • We discussed your fees regarding the Phaidon loss and opted not to include them in the Phaidon transaction. Note, the amounts paid in 2017 are being deducted as investment related expenses. • There is no net foreign income, based on the allocation of expenses and the BRH related foreign expenses. As such, we are taking the foreign taxes paid as a deduction this year (based on the carryforward). Leon is aware of this and made the decision to deduct. • Debra does not need her own income to contribute to an IRA under the current rules, as Leon has enough wages to cover both contributions. • 965 cfc rules have already been vetted by EY and are no applicable as we have no CFC E&P. • The interest paid is bifurcated between schedules A and E as appropriate, and run through the 4952. 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 EFTA01020736