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Leon on March 3rd. Likewise, the APO1 GRAT will need a RUVR for the January 24th in-kind distribution. Do you agree? Thanks in advance! Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dia Fax: 646-589-0330 1 EFTA_R1_01428395 EFTA02396316 Email: IRS Circular 230 D
Since Empire does not prepare=its valuations showing the value of a 1% interest in BFP but rather the va=ue of the entire interest transferred, if Leon re-GRATs BFP interests received on both January 24th and March 3rd, GRAT No. 2 will need a separate restric=ed use valuation report (RUVR) for its in-kind di
uations in this manner b=cause it did not take into account a discount associate with the percentage involved. Should we insist?<=u> Ada Clapp</=> Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022<=span> Direct Dial: <tel Fax: <tel Email: </=> IRS Circular 230 Disclosure: Pursuant to
Since Empire does not prepare its valua=ions showing the value of a 1% interest in BFP but rather the value of the entire interest transferred, if Leon re-GRATs BFP interes=s received on both January 24th and March 3rd,=GRAT No. 2 will need a separate restricted use valuation report (RUV=) for its in-kind di
eon on March 3rd. Likewise, the APO I GRAT will need a RUVR for the January 24°' in-kind distribution. Do you agree? Thanks in advance! Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 E FTA_R1_02204656 EFTA02720942 Direct Dial: Fax: ■ Email: • IRS Circular 230 Disclosure
Since Empire does not prepare its valuations showing the value of a 1% interest in BFP but rather the value of the entire interest transferred, if Leon re-GRATs BFP interests received on both January 24th and March 3s, GRAT No. 2 will need a separate restricted use valuation report (RUVR) for its in-kind di
Entities connected to both Elysium Management LLC and Leon re-GRATs

Jeffrey Epstein
PERSON
Richard Joslin
PERSONAda Clapp
PERSON
Marc Rich
PERSONEileen Alexanderson
PERSON
Alan Dershowitz
PERSON
Empire
ORGANIZATIONChristopher L Hurtado
PERSON