From: Paul Moths To: "'Jeffrey Epstein"' <[email protected]> Subject: FW: The FMV Valuation Alert - Sumner Redstone v. Commissioner Date: Tue, 15 Dec 2015 02:55:55 +0000 Original Message From: Lance S. Hall, ASA Sent: Monday, December 1 , 2015 08:10 PM Eastern Standard Time To: Paul Moths Subject: The FMV Valuation Alert - Sumner Redstone v. Commissioner Please click here if you cannot view this page. ELH A Tale of Two Brothers: (A Deceased Brother's Revenge) (Sumner Redstone v. Commissioner ra By Lance S. Hall, ASA! A few weeks ago, the Tax Court released its decision in the case of Edward Redstone v. Commissioned. While the Tax Court agreed with Edward, it disagreed in a later decision involving Edward's brother, Sumner - arguments about similar facts, but with a haunting twist of beyond the grave revenge. Backgrounda In the mid 1960s, Edward owned a one-third interest in National Amusement, Inc. ("NAI") along with his brother, Sumner, and his dad, Mickey. Later, Mickey exchanged his interest for preferred stock and gave a 20% voting interest to the Grandchidren's Trust. This left Edward and Sumner with a 40% voting interest. E4 Edward was given the responsibilty of running the back office operations and property development, while Sumner had the more glamorous responsibility of dealing with the movie studios for NAI's theater operations. As often happens, Edward felt marginalized by his more well-known, and capable, brother. When Sumner "hired Jerry Swedrow to take over Edward's responsibilities" in the family business, Edward became "incensed" and quit NAI. Upon leaving, Edward demanded that he be bought out, or he would sell his shares to an unrelated party. Mickey, desiring to keep the family business within the family, thwarted any possible sale to an outsider by refusing to give Edward his stock certificates. As the reason for not providing Edward with his stock certificates, Mickey argued that there was an oral EFTA0