From: "Barry J. Cohen" To: ' CC: Jeffrey Epstein <[email protected]>, Tom Turrin < >, Leon Black Subject: Re: 2012--PRIVILEGED AND CONFIDENTIAL Date: Sun, 30 Apr 2017 18:58:38 +0000 Agree on not giving APO our notice. But is it ok to give them our $884K number? Sent from my iPhone On Apr 30, 2017, at 2:32 PM, " ' < wrote: Barry-i don't think we need to give APO our # (or, certainly not the full 2nd notice). All we need is, for example, josh h's number and know his and leon's relative ownership % of brh in 2012 and the math is simple. I really think the obvious next step is for Jeffrey and tom to speak and for tom to reach out to the irs again. If that doesn't work, as you say, I think the tax guys--and in partic--shld architect the nature of the response. I'll get the answer tomorrow from EY on= question on the potentially prejudicial nature of acknowledging a mistake. Sent from my Verizon Wireless BlackBerry From: "Barry J. Cohen" Date: Sun 30A r 2017 17:31:57 +0000 To: Jeffrey Epstein<[email protected]>; Tom Turrin Cc: Leon Black Subject: RE: 2012--PRIVILEGED AND CONFIDENTIAL Here are my observations: 1. The first IRS letter references a "review" of BRH, but doesn't suggest that there will be changes to the BRH K-1 items. In fact, it implies the opposite. The letter points to the K-1 it thinks we should have used (not reflecting any changes from the original). It asks what K-1 LDB used because it can't find the BRH K-1 or its exact numbers on LDB's return. 2. The second IRS letter almost suggests the opposite. It is in effect saying that the original K-1 is wrong. P. 9 of the pdf indicates an adjustment of $884,006, referencing 98-054199, which is BRH's TIN; not to mention the p. 10 footnote which mentions BRH. 3. I'm not sure how the IRS traces this number to the LDB return, as the BRH K-1 was issued to BFP, and was not attached to LDB's return. LDB's 2012 return references a few items from BRH "via Black Family Partners,"