From: Jeffrey Epstein <[email protected]> To: Ellen Harrison < , Mortimer Zuckerman Subject: Re: M Date: Mon, 13 Jan 2014 14:23:18 +0000 all understood, but i dont see it on sale. ? what is the basis in the equity? If the debt were to be bought for roughtly the same amount as the equity, . eventually , the debt would receive the prefenrence giving the holder enough money to pay off the equity, . ( potential gain issues.? ) . I would thihnk an eventual bankruptcy . could be a solution , after his death, On Mon, Jan 13, 2014 at 10:20 AM, Ellen Harrison < > wrote: COD is first at the entity level but is allocable to Mort. As to when - many possibilities. Substantial modification of debt, actual forgiveness, contribution of the debt to the company, transfer of Mort's interest, to name a few. Sent from my iPhone On Jan 13, 2014, at 8:51 AM, Jeffrey Epstein <jeevacation®gmail.com> wrote: where and when is the COD? On Mon, Jan 13, 2014 at 9:25 AM, Ellen Harrison < > wrote: On your question about Mort's basis in the notes, I checked with Brian and He said the notes had not been written down so I gave you bad information. Sony. In my opinion, your purchase of the receivables from Mon would not cure the COD issue we are worried about. Even if the sale generated a capital loss, that would not offset ordinary income from COD. However, we will continue to explore this along with other ideas My partner is working on an accounting for the 1983 and 1996 trusts. She is still getting data. This has been in process for less than a month. I expect that it will be some time before it is done because I am told that the records prior to 2000 are limited. SRR is appraising R&R. We are hoping, of course, that the cash flow will be sufficient to cover the preference. Since we don't have the appraisal or the preference yet we don't know whether this will be a problem. If it is, I would use debt to reduce value so cash flow would cover the preference. This is a