From: Deborah Pechet Quinan (mailto:[email protected]] Sent: Thursday, December 07, 2017 =:18 PM To: Max Kohlenberg Cc: Noam Chomsky ([email protected]) Subject: Distributions for Tax =ayments from Carol S. Chomsky Marital Trusts Max - At Noam Chomsky's direction I am writing to formally =equest two distributions on his behalf to be made from the Carol S. =homsky Marital Trusts, as follows: $150,000 for 2017 federal estimated taxes =hich we ask that you remit directly to the US Treasury on Noam's =ccount (I do not have a voucher); and $109,271 for 2016 taxes paid from =oam's IRA and penalties incurred. As I know you are aware, distributions =rom the marital trusts are to be made in your sole discretion. =our co-trustee, Harry Chomsky, has no =ay in making =iscretionary distribution decisions per the terms =f the trust. Therefore there is no need for you to confer =ith Harry and you are able to accede to this requestpromptly and without delay. As I know you are also aware, the trust =ontains no standard requiring you to consider Noam's other =inancial resources. You are obligated to reasonably exercise your =iscretion, and making the 2017 income tax payment for Noam from these =rusts is more than reasonable under any analysis. In addition, Noam's income tax liability for 2016 =as unnecessarily increased due to your refusal to make =he 2016 income tax payments from the trust. As a result, Noam had =o withdraw $109,000 from his IRA to make 2016 income tax payments and =271 in tax penalties were incurred. These =ithdrawalsunnecessarily and unreasonably increased Noam's =016 and 2017 income tax liabilities because the marital trusts had more =han sufficient funds to allow you to make these 2016 tax payments from =ssets that would not incur ordinary income tax on every dollar =istributed. Again, this distribution of $109,271 is a reasonable =xercise of your discretion under any analysis. =nbsp; Please confirm that you will take care of these =ayments before the close of business tomorrow. Please remit =he $150,000 check directly to the federal taxing authorities and fax me = copy of the check and remittance correspondence. See my fax =umber below. I will send you another email shortly with =irections for you to remit the $109,271 distribution. Deborah Deborah Pechet Quinan, Esq. LL.M. Shareholder Chair, Trusts & Estates =roup 255 =tate Street, 7th Floor I Boston, =A 02109 Direct: 617.570.3521 I Cell: 617.832.5726 Assistant - Jayne Mahoney: 617.570.3581 Office: 617.742.4200 I Fax: 617.742-2355 6 EFTA_R1_01704027 EFTA02548945
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