From: Jeffrey Epstein <[email protected]> To: Ellen Harrison Subject: Re: M Date: Mon, 13 Jan 2014 14:41:56 +0000 I understand that, 1. at some time probably a meeting or conference , 2 the issues of privilege should be discussed , On Mon, Jan 13, 2014 at 10:37 AM, Ellen Harrison < wrote: I don't follow your email. The purchase price for the debt should not exceed the value of the company without counting the debt. If debt exceeds equity then the equity has no value. After I speak with my tax people, I will let you know their view of what your proposal to purchase the debt would accomplish. Unfortunately the insolvency exceptions to forgiveness of debt don't work for a partnership if the partner is solvent. Sent from my iPhone On Jan 13, 2014, at 9:23 AM, Jeffrey Epstein <[email protected]> wrote: 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. Sorry. In my opinion, your purchase of the receivables from Mort would not cure the COD issue we are worried about. Even if the sale generated a capital lo