From: Richard Joslin < Sent: Monday, April 17, 2017 11:02 PM To: jeffrey E. Subject: RE: Re: This was a sale and should be claimed in the year of sale as reduction of sales proceeds (cost of sale). From: jeffrey E. [mailto:[email protected]] Sent: Monday, April 17, 2017 6:29 PM To: Richard Joslin < Subject: Re: Re: and the fees for structuring the phaidon transaction. ? as part of his income tax planning.? I think so. dont you? On Mon, Apr 17, 2017 at 6:25 PM, Richard Joslin < I will get you the backup for estate planning nondeductibity <mailto » wrote: From: jeffrey E. [mailto:[email protected] <mailto:[email protected]> Sent: Monday, April 17, 2017 6:18 PM To: Richard Joslin < <mailto > > Subject: Re: order to be deductible, the IRS <http://www.investopedia.com/terms/i/irs.asp> requires that estate planning fees <https://www.irs.gov/pub/irs-pdf/p550.pdf> must be paid: (1) for the production or collection of income; (2) for the management, conservation or maintenance of property held for the production of income; or (3) in connection with the determination, collection or refund <http://www.investopedia.com/terms/r/refund.asp> of any tax. So how might this apply to estate planning fees? If, for example, the estate plan <http://www.investopedia.com/advisor-network/articles/05173.6/why-its-so-important-update-your-estate-plan/> involves advice on the construction of income generating instruments, such as an income trust <http://www.investopedia.com/terms/i/incometrust.asp> , or provides guidance on the use of property transfer methods to avoid Federal or State Estate or Inheritance tax <http://www.investopedia.com/terms/e/estatetax.asp> , these would meet the IRS restrictions for the ability to deduct such expenses. Other examples might include investment advice <http://www.investopedia.com/terms/i/investment-advice.asp> for trusts held by the estate, trust tax preparation fees and account custodial fees while held by the estate EFTA_R1_01896067 EFTA02652698

Read more: Are estate planning fees tax deductible? I Investopedia chttp://www.investopedia.com/ask/answers/113015/are-estate-planning-fees-tax-deductible.asp#ixzz4eYlkslWb> http://www.investopedia.com/ask/answers/113015/are-estate-planning-fees-tax-deductible.aspfrixzz4eYlkslWb <http://www.investopedia.com/askianswers/113015/are-estate-planning-fees-tax-deductible.asp#ixzz4eYlkslWb> Follow us: Investopedia on Facebook <http://ec.tynt.com/b/rf?id=arwjQmCEqr4I6Cadbi-bnq&u=Investopedia> On Mon, Apr 17, 2017 at 6:13 PM, Richard Joslin < <mailto » wrote: Income tax planning and fees for services to calculate the income tax are deductible From: jeffrey E. [mailto:[email protected] <mailto:[email protected]> ) Sent: Monday, April 17, 2017 6:09 PM To: Richard Joslin < <mailto > > Subject: are fees for tax planning deductible? please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for 2 EFTA_R1_01896068 EFTA02652699

the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 3 EFTA_R1_01896069 EFTA02652700