Epstein Secrets

fices in New York, NY, Rochester, NY, and West Hartford, CT, Empire is one of the largest independent valuation consulting firms in the Northeast. Empire's team of more than fifty (50) valuation professionals all hold advanced educational degrees in various areas of study, included finance, accounting

s leading trust & estate attorneys, accountants, and financial planning firms. With offices in New York, NY, Rochester, NY, and West Hartford, CT, Empire is one of the largest independent valuation consulting firms in the Northeast. Empire's team of more than fifty (50) valuation professionals all ho

IN ESTATE FREEZE ENTITIES November 2007 350 Fifth Avenue, Suite 5513, New York, NY 10118 Phone: 212.714.0122 777 Canal View Boulevard, Suite 200, Rochester, NY 14623 Phone: 585.475.9260 61 South Main Street, Suite 201, West Hartford, CT 06107 Phone: 860.233.6552 EFTA00617244 The purpose of a Freeze

for each valuation, we are providing a single response that is applicable in both cases. We understand the IRS is seeking an explanation as to why Empire selected a lower, combined, lack of control and marketability discount of 15% rather than a higher one. Empire did consider, as a starting point i

Consultants, LLC ("Empire") provide a response to the IRS's request for an explanation of the lack of control and marketability discount applied in Empire's valuations of: (1) a 37.75% interest in Black Family Partners, LP ("BFP") as of October 25, 2013; and (2) a 34.53% interest in BFP as of December

ess than the low end of the range from the studies. 350 Fifth Avenue, Suite 6115, New York, NY 10118 Tel: (212) 714-0122 empireval.com New York Rochester Boston West Hartford EFTA00619442 PRIVILEGED - ATTORNEY WORK PRODUCT - DRAFT Alan Halperin, Esq. May 10, 2016 Page 2 Empire selected 15% as

udy as guidance for selecting an applicable lack of control and marketability discount. While these items are referenced separately in our report, Empire determined that it was reasonable to select a combined lack of control and marketability discount that was below a combined level of the low end of

Consultants, LLC ("Empire") provide a response to the IRS's request for an explanation of the lack of control and marketability discount applied in Empire's valuations of: (1) a 37.75% interest in Black Family Partners, LP ("BFP") as of October 25, 2013; and (2) a 34.53% interest in BFP as of December

stributed to a withdrawing partner, are subject to 350 Fifth Avenue. Suite 6115. New York. NY 10118 Tel: (212) 714.0122 empirevaLcom Ncw York • Rochester Boston West Hartford EFTA_R1_02076111 EFTA02702706 PRIVILEGED - ATTORNEY WORK PRODUCT - DRAFT Alan Halperin, Esq. April 27, 2016 Page 2 val

is summary letter will be used by you and the Client for estate planning purposes related to a GRAT annuity payment. To estimate the PIK Interest, Empire relied on the valuation report dated August 21, 2015, with an effective date of June 3, 2015 (the "Empire Report"). By reference, the Empire Report

ted partnership interest in Black Family Partners, LP is reasonably stated as $780,000,000 as of December 4, 2013. 777 Canal View Blvd., Suite 200, Rochester, NY 14623 Tel: (585) 475-9260 empireval.com Ncw York • Cleveland • Rochester • West Hartford EFTA_R1_01942572 EFTA02671576 EXHIBIT 0 CA