Epstein Secrets

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

ility discount at a level of 15%, well below the low end of the range of the sources cited, as upper end guides, in the Empire reports. Sincerely, Scott A. Nammacher, ASA, CFA Managing Director EFTA00619444

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

tability discounts applicable to the interests in BFP that were at the low end of the range of the sources cited in the Empire reports. Sincerely, Scott A. Nammacher, ASA, CFA Managing Director Privileged EFTA_R1_02076112 EFTA02702707

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

conclusion that there would be no changes or adjustments to any of the valuation adjustments applied in the Empire Report, for a 5.0143% interest. Scott A. Nammacher, ASA, CFA Managing Director Payment In Kind. To be clear, the PIK is a limited partnership interest in BFP. EFTA_R1_01942583 EFTA02671587 Confi