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EFTA02651245

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From: jeffrey E. <[email protected]> Sent: Sunday, April 30, 2017 10:51 PM To: Barry Cohen; Thomas Turrin; [email protected] Cc: Leon Black Subject: Re: We were told that neither Deloitte or apollo tax knew of this . That w=s the first question On Sun, Apr 30, 2017 at 6:18 PM Thomas Turrin <[email protected]> wrote: Please see my comments below in red. <=iv> Original Message From: <mailto: Sent: Sunday, April 30, 2017 11:33 AM To: Jeffrey Epstein; Thomas Turrin; Barry Cohen Cc: Leon Black Subject: > [mailto:[email protected] Guys-can I just mention and confirm some things: 1. As an fyi, but as I believe you know, RJ is pulling together the ba=k-up and presentation on the other items of BRH income highlighted in the =riginal IRS notice this week end. Hopefully we will not have to submit. =A0 2. As we all know I aint no tax guy but I read the assessment letter v=ry carefully and my "uninformed" view is exactly tom and jeffrey=1439;s first reaction (which may or may not have changed), ie, that the IRS=C2 found/acknowledges 378,805,695 of what they believe should be 379,707,381 or a delta of 884,006. (They also found a del=a of 17,680 in itemized deductions.) Definitionally, these numbers have to=include BRH numbers and as jeffrey said to me, they answered the question =hey posed in the initial notice. The "delta" in i=come is not a result of an audit of Leon's tax return. =AO The "delta" is Leon's (BFP's) al=ocable share of the adjustment of BRH Holdings, LP ordinary =ncome as a result of an audit of the ta= return of BRH Holdings. The issue is on th= BRH partnership return. Suzan=e Wong (or someone at Apollo or Deloitte) should be able to provide a copy of the IRS audit report explaini=g the adjustment of BRH. I will not be able to speak =o the agent about BRH specifically since I am not the tax preparer of BRH.=/b> When the IRS audits a partnership and makes an =djustment to the partnership's income or deductions,=the IRS

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