From: jeffrey E. <[email protected]> Sent: Tuesday, September 19, 2017 9:09 PM To: Barry J. Cohen Subject: Re: 000's I actually dont care whether or not he agrees . I would ask that you merely inquire as to how many 1040 fed audits 1040 large case or 10 40 wealth squad audits hes actually mana=ed or partcipated in. how much loss =o you think you can generate this year with a phaidon transaction.? On Tue, Sep 19= 2017 at 4:29 PM, Barry J. Cohen < <mailto » wrot=: He is agreeing with you on gift tax returns. =an't leave everything blank. From: jeffrey E. [mailto:[email protected] Sent: Tuesday, September 19, 2017 4:25 PM To: Barry J. Cohen < <mailto Subject: Re: 000's > > think about it, again, ask j=e how many 1040 audits he has done. . what size. h=w complex. when we file a grat, we cal=late the gift explicity at zero. . it =s the calculation of a gift minus the annuity. It is sim=le math. no more 2 minus ( 1+=) does not equal NONE On Tue, Se 19, 2017 at 4:19 PM, Barry J. Cohen <=a href="mailto target="_blank" <=a» wrote: Fair enough. From: jeffrey E. [mailto:[email protected] Sent: Tuesday, September 19, 2017 4:19 PM To: Barry J. Cohen < <mailto Subject: Re: 000's dumb! In III, as i told you, =omputers dont read letters > > EFTA_R1_01823118 EFTA02618887

On Tue, Sep 19, 2017 at 4:15 PM, Barry J. Cohen <=a href="mailto ' target="_blank" <=a» wrote: Sorry I misunderstood on the 000s. Gift tax r=turns have to report a number somewhere, so maybe statute doesn't start. But if you filed an income tax return for an entity with no i=come or expenses, Joe V assumes the statute would start. In any even=, we don't file returns that way. As I said, we would say =E2 None" where appropriate. From: jeffrey E. [mailto:[email protected] Sent: Tuesday, September 19, 2017 4:09 PM To: Barry J. Cohen < <mailto Subject: Re: 000's i did not suggest you use the 000 method. Im sorry but i dont have the time . do yo= think if you filed a gift tax return and left everything blank the =tatue would run? On Tue, Sep 19, 2017 at 4:03 PM, Barry J. Cohen <=a href="mailto target="_blank" <=a» wrote: John Cook at EY said they would not sign a return th=t uses the 000s method. They said that there are too many footing pr=blems. Numbers won't tie to K-1s, W-2s, 1099s, etc. Also, if you only use it on part of the return, the various numbers on the=return would not match internally. He also pointed out that this met=od effectively truncates numbers; though I'm not sure what roundin= rules you use. E.g., 101,499 become 101? What happens to the other $499? Joe V likes the idea of putting in 0's inste=d of blanks. He says he uses "none". He did no= understand why this would affect the statute of limitations. Barry J. Cohen I Elysium Management,=LLC 445 Park Avenue Suite 1401 <https://maps.google.com/?q=445+Park+Ave=ue+Suite+1401%0D+New+York,+NY+10022&entry=gmail&source=g> New York, NY 10022 <https://maps.google.com/?q=445+Park+Ave=ue+Suite+1401%0D+New+York,+NY*10022&entry=gmail&source=g> = Tel. 2 EFTA_R1_01823119 EFTA02618888

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