e he was going to contact you directly. Please let me know. If not, I will take care of it on his behalf. MARYLYN GUZMAN, Administrative Assistant Tax Department Marks Paneth LLP 68 , New York, NY, 10017 P. F. E. Original Message From: Lesley Groff [mailto: Sent: Tuesday, May 06, 2014 11:29 AM To:

l free to contact me anytime to arrange things like this. Sometimes Alan is quite behind on his emails :) MARYLYN GUZMAN, Administrative Assistant Tax Department Marks Paneth LLP 685 Third Avenue, New York, NY, 10017 P. F. E. Original Message From: Lesley Groff [mailto: Sent: Tuesday, May 06, 2014 12

7 E. 2 F. From: Guzman, Marylyn Sent: Monday, December 16, 2013 12:18 PM To: Dlugash, Alan Subject: MARYLYN GUZMAN Administrative Assistant Tax Department Marks Paneth & Shron LLP 685 Third Avenue, New York, NY, 10017 P. F. E. EFTA00377686 IRS CIRCULAR 230 DISCLOSURE: Treasury Regulations requi

he owner shall be deemed to be located at the domicile of the owner for purposes of taxation (italics added]." In other words, the opinions reflect Tax Department policy that doesn't necessarily square with the literal language of the underlying law. Stated differently, the opinions are designed to have a chil

e owner shall be deemed to be located at the domicile of the owner for purposes of taxation [italics added]." In other words, the opinions reflect Tax Department policy that doesn't necessarily square with the literal language of the underlying law. Stated differently, the opinions are designed to have a ch