Document Mentions (4 shared documents)

EFTA00389399

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3:30 Good morning Alan. Just reconfirming Jeffrey will come see you, Brad and patrick today at 3:30 in your office. Thanks, Lesley Sent from my iStone This message is intended only for the use of the Addressee and may contain information that is privileged and confidential. If you are not the inte

romoting, marketing or recommending to another party any transaction or matter addressed herein. Alan S. Halperin I Partner Paul, Weiss, Rificind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 (Direct Phone) (Direct Fax) I www.paulweiss.com From: "Lesley Groff' Sent: 06/05/2013 10:

EFTA02724150

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the light of the Tax Court's correct distinction of this case from, among others. Estate of Scull v. Commissioner. 67 T.C.M. (CCH) 2953 (1994). and Stone v. United States. No. 06-0259. 2007 WI. 2318974. at •3 (N.D. Cal. Aug. 10. 2007). The courts in both of those cases awarded nominal discounts, but,

as not in the Fifth Circuit decision. I am pulling up the Tax Court decision and will let you know. Alan S. Halperin Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP From: Jeffrey E. [mailto:[email protected]] Sent: Wednesday, September 17, 2014 9:07 AM To: Halperin, Alan S Subject: Re: Elkins Case what w

EFTA00584463

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APITAL MANAGEMENT LIMITED APOLLO LIFE ASSET LTD STONE TOWER OFFSHORE LTD APOLLO ALST GENPAR LTD APOLL

Apollo's tax advisor) and diligently reviewed the history and factual circumstances with their accountants and the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the