To: Jeffrey Epstein[leevacationegmail.com] Fran: Ada Clapp Sent Mon 9/23/2013 6:56:58 PM Subject Re: Petition for Advisory Opinion HI Jeffrey--sorry, I tried to send you this response from my iPad this morning and just realized it did not go through to you: I do not think we should mention that sales tax was paid by the grantor for the reasons we discussed relating to our not applying for the opinion in the first place. I don't think we want that to be a determinative factor in the ruling. I worry that it opens the door for a fishing expedition if NY ever looks into such a reacquisition. If still want it included in the Petition and it does become a determinative factor to issuing the opinion, it means that a grantor will only be able to substitute art for which he or she can prove sales tax was paid. I would rather not have that limitation. Let me know if you still want it included. Regarding the administrative powers language, the Petition quotes the entire trust language which states that the grantor is exercising the power in a non-fiduciary capacity. I don't see what traction is gained by simply repeating this as part of the argument for a favorable opinion. What is your reasoning for why this bolster the lack of consideration argument? Please explain so I know what you arc trying to accomplish. Thanks. Ada Clapp Black Family Partners Vo Apollo Monegomont 9 W 57th Street Now York NY 10019 IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. This communication, an