From: Jeffrey Epstein <jeevacationggmail.com> To: Melanie Spinella Subject: Fwd: Date: Mon, 13 Jan 2014 12:12:04 +0000 Forwarded message From: Alan S Halperin Date: Mon, Jan 13, 2014 at 7:57 AM Subject: Re: To: Jeffrey Epstein <jeevacation(ipgmail.com> In providing you with my previous answer, I had assumed that the decedent owned an interest in the entity. My previous email therefore described how his ownership interest in the entity would be reflected. The trusts ownership interest, in turn, would not be shown directly on any schedule on the 706. Rather, in response to questions in the 706, you attach riders describing various trusts associated with the decedent. Generally, we do not disclose on the 706 the assets of trusts not subject to estate tax. However, during the audit, the IRS often asks about the trust assets. If the decedent owns the art directly, it is reflected on Schedule, with a supporting appraisal. The artwork then will be sent to the Art Panel for valuation by the IRS. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Click Here for More Information Alan S. Halperin I Partner Paul. Weiss. Rifkind. Wharton 8 Garrison LLP (Dir ac Americas I 19-6064 Dir t Phone) Direct Fax) I AN vw.paulweiss.com From: 'Jeffrey Epstein" < °vacation mail.com> To: Man S Halperin Dale: 01/13/2014 06:49 AM Subject: Re: and if owned personally EFTA00871449