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EFTA01047839

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From: "jeffrey E." <jeevacationggmail.com> To: Barry Cohen , Thomas Turin < Cc: Leon Black Subject: Re: Date: Sun, 30 Apr 2017 22:50:31 +0000 We were told that neither Deloitte or apollo tax knew of this . That was the first question On Sun, Apr 30, 2017 at 6:18 PM Thomas Turin < wrote: Please see my comments below in red. Original Message From: [mailto: Sent: Sunday, April 30, 2017 11:33 AM To: Jeffrey Epstein; Thomas Turrin; Barry Cohen Cc: Leon Black Subject: Guys-can I just mention and confirm some things: 1. As an fyi, but as I believe you know, RJ is pulling together the back-up and presentation on the other items of BRH income highlighted in the original IRS notice this week end. Hopefully we will not have to submit. 2. As we all know I aint no tax guy but I read the assessment letter very carefully and my "uninformed" view is exactly tom and Jeffrey's first reaction (which may or may not have changed), ie, that the IRS found/acknowledges 378,805,695 of what they believe should be 379,707,381 or a delta of 884,006. (They also found a delta of 17,680 in itemized deductions.) Definitionally, these numbers have to include BRH numbers and as jeffrey said to me, they answered the question they posed in the initial notice. The "delta" in income is not a result of an audit of Leon's tax return. The "delta" is Leon's (BFP's) allocable share of the adjustment of BRH Holdings, LP ordinary income as a result of an audit of the tax return of BRH Holdings. The issue is on the BRH partnership return. Suzanne Wong (or someone at Apollo or Deloitte) should be able to provide a copy of the IRS audit report explaining the adjustment of BRH. I will not be able to speak to the agent about BRH specifically since I am not the tax preparer of BRH. When the IRS audits a partnership and makes an adjustment to the partnership's income or deductions, the IRS sends adjustment notices to the partners such as the one received late Friday in which they ind

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