EFTA Document EFTA01801229

From: Ada Clapp Sent: Monday, March 9, 2015 4:26 PM To: Jeffrey E. Cc: Brad Wechsler Subject: FW: Ben's 2012 Gift Tax Return FYI<=p> From: Ada Clapp Sent: Monday, March 09, 2015 12:03 PM To: Thomas Turrin; Richard Joslin Cc: Halperin, Alan 5; Brad Wechsler; Eileen Alexanderson Subject: RE: Ben's 2012 Gift Tax Return Michael Shenker called=Alan today in connection with the IRS's audit of Ben's gift ta= return. Michael wanted Alan to confirm for him that he understood t=e facts surrounding the Note and the gift. After Alan did so, Michael indicated that he wanted to think about it further but was=inclined toward a "no change" determination. Alan will keep us post=d if he hears anything further. We would appreciate it if you would =o the same. Thanks! Ada Clapp Chief Legal Officer Elysium Management LLC=o:p> 1 EFTA_R1_00141904 EFTA01801229 This communication =nd any attachment is for the intended recipient(s) only and may contain in=ormation that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemina=ion of this communication and its attachments is prohibited. Please =elete all copies of this communication and its attachments and notify me i=mediately that you have received them in error. Thank you. From: Thomas Turri Sent: Wednesday, F To: Ada Clapp Cc: Halperin, Alan S; Richard Joslin; Eileen Alexanderson; Brad Wech=ler Subject: Re: Ben's 2012 Gift Tax Return I agree...I normally let them get =ack to me. If we had not responded, he most likely would have =ontacted me. Sent from my Verizon Wireless 4= LTE DROID Ada Clapp > wrote: No need (unless you th=nk it advantageous to do so). Just wondered. Thanks. Ada Clapp Chief Legal Officer Elysium Management LLC=/span> 2 EFTA_R1_00141905 EFTA01801230 This communication =nd any attachment is for the intended recipient(s) only and may contain in=ormation that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemina=ion of this communication and its attachments is prohibited. Please =elete all copies of this communication and its attachments and notify me i=mediately that you have received them in error. Thank you. From: Thomas Turrin Sent: Wednesday, Fe ruary , : To: Ada Clapp Cc: Halperin, Alan S; Richard Joslin; Eileen Alexanderson; Brad Wech=ler Subject: RE: Ben's 2012 Gift Tax Return Ada,=/p> I have not heard from =he agent. I will follow up tomor=ow. Tom<=p> THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP 3 EFTA_R1_00141906 EFTA01801231 Website: www., em-co.com <http://www.rem-co.com> From: Ada Clapr Sent: Wednesday, February 04, 2015 6:12 PM To: Thomas Turrin Cc: Halperin, Alan S; Richard Joslin; Eileen Alexanderson; Brad Wech=ler Subject: RE: Ben's 2012 Gift Tax Return Hi Tom, Hope you are well.&nbs=; Any response from the auditor? Ada Clapp Chief Legal Officer Elysium Management LLC=/span> 4 EFTA_R1_00141907 EFTA01801232 This communication =nd any attachment is for the intended recipient(s) only and may contain in=ormation that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemina=ion of this communication and its attachments is prohibited. Please =elete all copies of this communication and its attachments and notify me i=mediately that you have received them in error. Thank you. From: Thomas Turrin Sent: Thursday, January , : To: Ada Clapp Cc: Halperin, Alan 5; Richard Joslin; Eileen Alexanderson Subject: RE: Ben's 2012 Gift Tax Return Ada,=/p> Attached is copy of co=plete response — the original is being mailed today via<=o:p> certified mail. &=bsp; The password to the pd= is my office zip code. ..below. Tom<=p> THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP 5 EFTA_R1_00141908 EFTA01801233 Website: www.=em-co.com <http://www.rem-co.com> From: Ada Clapp Imailto:[email protected] Sent: Thursday, January 08, 2015 11:08 AM To: Thomas Turrin Cc: Halperin, Alan 5; Richard Joslin; Eileen Alexanderson Subject: RE: Ben's 2012 Gift Tax Return Thank youh/o:p> Ada Clapp Chief Legal Officer Elysium Management LLC=/span> 6 EFTA_R1_00141909 EFTA01801234 This communication =nd any attachment is for the intended recipient(s) only and may contain in=ormation that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemina=ion of this communication and its attachments is prohibited. Please =elete all copies of this communication and its attachments and notify me i=mediately that you have received them in error. Thank you. From: Thomas Turrin Sent: Thursday, January 08, 2015 10:56 AM To: Ada Clapp Cc: Halperin, Alan 5; Richard Joslin; Eileen Alexanderson Subject: RE: Ben's 2012 Gift Tax Return Ada,=/p> I think the response i= fine as is. Will include cc to Ben on letter. Rich is sending POA to=ay...just got his email. I will forward complet= copy to you for your file. Tom<=p> THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP 7 EFTA_R1_00141910 EFTA01801235 Website: www.=em-co.com <http://www.rem-co.com> From: Ada Clapp Sent: Thursday, January 08, 2015 10:48 AM To: Thomas Turrin Cc: Halperin, Alan 5; Richard Joslin; Eileen Alexanderson Subject: RE: Ben's 2012 Gift Tax Return Hi Tom, Just checking in to se= if you would like any changes to the audit response letter (as a reminder= I am out next week). Also, would you kindly add Ben as a "cc&=8221; to the letter. I would be grateful if you would also send me a copy of the final letter, with attachments for our files.&n=sp; Do you now have the Fo=m 2848? Best regards, Ada Clapp Chief Legal Officer Elysium Management LLC=/span> 8 EFTA_R1_00141911 EFTA01801236 This communication =nd any attachment is for the intended recipient(s) only and may contain in=ormation that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemina=ion of this communication and its attachments is prohibited. Please =elete all copies of this communication and its attachments and notify me i=mediately that you have received them in error. Thank you. From: Ada Clapp Sent: Tuesday, January 06, 2015 11:09 AM To: CPA Thomas Turrin Cc: Halperin, Alan S Subject: Ben's 2012 Gift Tax Return Importance: High Hi Tom, Happy new year! We haven't spoken in a w=ile and I hope that you have been well. I just left you a voicemail regarding the audit of B=n's 2012 Gift Tax Return. Attached is a proposed response to M=chael Shenker's most recent request for information. As you kn=w, our reply is due by January 15th. Alan and I prepared the attached letter for your signature=(that is, if you approve of it, of course). As you can see, the prop=sed reply is as brief as possible while still being responsive to Mr. Shenker's requests. Given the complex =eries of steps involved in the issuance of the $5.12 million note, Alan an= I are pretty certain Shenker will have additional questions and ask for a=ditional documents. I just wanted to be sure that you were familiar with all the background. I am available =his week (but out of the country all next week), should you wish to discus= or to have me make changes to the letter. In my absence, please spe=k with Alan. 9 EFTA_R1_00141912 EFTA01801237 Rich J. is getting Ben to sign the IRS power of atto=ney in favor of you and Alan. I assume you will need to send that with the attached letter, so I h=ve referenced it therein. Please follow up with Rich to obtain=he 2848. Thanks! Ada Clapp Chief Legal Officer Elysium Management LLC This communication and any attachment is for the =ntended recipient(s) only and may contain information that is privileged, =onfidential and/or proprietary. If you are not the intended reci=ient, you are hereby notified that further dissemination of this communication and its attachments is prohibited.&nbs=; Please delete all copies of this communication and its attachments and n=tify me immediately that you have received them in error. Thank you.=nbsp; &=bsp; CONFIDENTIALITY STATEMENT: The information contained in this electronic communication, including any and all attachments and enclo=ures, may be privileged and is strictly confidential, intended solely for =he use of the person(s) identified above to receive this communication. If=you are not the person(s) identified above to receive this communication, you are hereby notified that you may =ot disclose print, copy, disseminate, or otherwise use the information con=ained herein. If you are an employee or agent of the person(s) identified =bove to receive this communication and, as such, you have been authorized to deliver this communication to su=h person(s), you may disclose, print, copy, disseminate, or otherwise use =he information contained in this communication solely for the purpose of s=ch delivery. Unauthorized interception and/or use of this communication are/is strictly prohibited and may 10 EFTA_R1_00141913 EFTA01801238 be pun=shable by law. If you have received this communication in error, please re=ly and notify the sender (only) of that fact and delete the communication,=including any and all attachments and enclosures, from your computer or other electronic device on which you=may have received this communication. 11 EFTA21_00141914 EFTA01801239