Subject: RE: Tax Returns et al Do the recourse liabilities need to be itemized on her K-I in order for her to have basis or can you allocate her proportionate share from the K-I from TCCI to TCGM? gay: I Daniel Rabia I Chief Financial Officer' 66 East 55th Street, New York NY 10022 P Mc. f: 212 381 7801lwvAv.coreaccess.net From: Kathleen Buzbee Sent: Monday, April 06, 2009 3:17 PM To: Daniel Rabia Subject: RE: Tax Returns et al Ira Because Jennie is (was?) the managing member of the LLC's and had personally guaranteed loans, the debts were allocated to her K-I in 2005 which then created basis for her to take the losses. The losses created a net operating loss in her return which allowed her to tile a claim for refund of previous taxes paid. The timing issue comes as follows- if, in the future, the Club reaches the point when it makes income it will be allocated to Jenny until it offsets all losses previously allocated to her. This income is then included in her personal return in the year received, and can then be offset by the normal itemized deductions. Kathleen F. Buzbee CPA/ABV, CVA, MST Principal Konowitz, Kahn & Company, P.C. 127 Washington Ave North Haven CT 06473.0190 Phone: Fax: 203-234-1553 Any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. PRIVILEGED AND CONFIDENTIAL: This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential or privileged infonnation. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is strictly prohibited. If you arc not the intended recipient, please notify the sender immediately by return email and delete this communication and destroy all copies. From: Daniel Rabia [- Sent: Monday, April 06, 2009 3:04 PM To: Kathleen Buzbee Cc: Jamie Saunders Subject: Tax Returns ct al EFTA_R1_01511914 EFTA02438642
Ili Kathy, Jennie has asked me to follow up with you re your e-mail to her from yesterday. It turns out that the recourse and non-recourse liabilities are itemized on the K-I from TCCI to TCGM (The Core Group Management) since that is where the PG's actually reside. In the K-1's we sent you we only included the K-I's in Jennies name based on a call you and I had several weeks ago. One item we need clarity on is with regard to the following statement in your e-mail to Jennie: "I also had warned you many times that this refund was due to timing and that some day you would have to return it." What is the meaning of having to return the refund one day? Under what circumstances does the refund have to be returned? We have a call at 5pm to discuss with our tax preparer the open issues you have raised and would be great to know the answer to the above beforehand. I will forward a summary of the call to you and we can them determine if you arc more comfortable filling Jennie's return as there is no material change other than ownership changes that took place in 2006. Thanks, Daniel CORE: I Daniel Rabia I Chief Financial Officerl 66 East 55th Street, New York NY 10022 Id: 212 381 7801 Iwww.coreaccess.net M: DISCLAIMER Important! This message is intended for tlx: above named person(s) only and is CONFIDENTIAL AND PROPRIETARY. If you are not the intended recipient of this e-mail and have received it in error, please forward to [email protected] with EFTA_R1_01511915 EFTA02438643
'Received in Erre? as the subject and then delete it from your mailbox. Accessing, copying or re-using any of the information contained in this e-mail by anyone other than the intended recipient is unauthorized. Thank you. Any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting. marketing or recommending to another person any transaction or matter addressed herein. PRIVILEGED AND CONFIDENTIAL: This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential or privileged information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email and delete this communication and destroy all copies. DISCLAIMER Important! This message is intended for the above named person(s) only and is CONFIDENTIAL AND PROPRIETARY. If you are not the intended recipient of this e-mail and have received it in error, please forward to [email protected] with 'Received in Error as the subject and then delete it from your mailbox. Accessing. copying or re-using any of the information contained in this e-mail by anyone other than the intended recipient is unauthorized. Thank you. Any tax advice contained in this conununication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. PRIVILEGED AND CONFIDENTIAL: This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential or privileged information. If you arc not the intended recipient, any use, copying, disclosure, dissemination or distribution is strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email and delete this communication and destroy all copies. DISCLAIMER Important! This message is intended for the above named person(s) only and is CONFIDENTIAL AND PROPRIETARY. If you are not the intended recipient of this c-mail and have received it in error, please fonvard to [email protected] with 'Received in Error' as the subject and then delete it from your mailbox. Accessing, copying or re-using any of the information contained in this e-mail by anyone other than the intended recipient is unauthorized. Thank you. Any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting. marketing or recommending to another person any transaction or matter addressed herein. PRIVILEGED AND CONFIDENTIAL: This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential or privileged information. If you arc not the intended recipient, any use. copying. disclosure. dissemination or distribution is strictly prohibited. If you arc not the intended recipient, please notify the sender immediately by return email and delete this communication and destroy all copies. MOO The information contained in this communication is confidential. may be attorney-client privileged, may constitute inside infonnation, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein 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 jeevacationtegmail.corn, and EFTA_R1_01511916 EFTA02438644
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