From: Sent: Sunday, April 30, 2017 6:33 PM To: Barry Cohen; Jeffrey Epstein; Tom Turrin Cc: Leon Black Subject: Re: 2012--PRIVILEGED AND CONFIDENTIAL Barry-i don't think we need to give APO our 74 (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 jeffrey in partic--shld architect the nature of the response. I'll get the answer tomorrow from EY on jee's question on the potentially prejudicial nature of acknowledging a mistake. Sent from my Verizon Wireless BlackBerry From: "Barry J. Cohen" < Date: Sun, 30 Apr 2017 17:31:57 +0000 To: < I>; Jeffrey Epstein<[email protected]>; Tom Turrial- 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," so maybe the IRS assumes that LDB pays taxes attributable to BRH. 4. The IRS seems to be pointing out 2 different problems in its respective letters