From: jeffrey E. <[email protected]> Sent: Monday, April 17, 2017 10:20 PM To: Alan S Halperin Subject: Fwd: is it your position that a summary of the trust document=C2 with a note that says full document available upon request. and atta=hed to a tax return leaves it open to be deemed / =ot adequately disclosed ??! =orwarded messa e From: Thomas =urrin < <mailto > > Date: Mon, Apr 17, 2017 at 6:17 PM Subj=ct: RE: To: "jeffrey E." <[email protected] <mailto:jeevacation@gm=il.com» It is considered =9Cbest practice" to attach the complete trust document. You<=> avoid running afoul of ad=quate disclosure. Some agent could "deem =90 a brief summary of the trust to be inadequate. T=is issue is avoided by having the trust document attached. I'm sure Alan Hal=erin would agree. From: jeffrey =. [mailto:[email protected] <mailto:[email protected]> I Sent: Monday, April 17, 2017 5:58 PM To: Thomas Turrin Subject: Note that the Form 709 instructions also indicate th=t either a copy of the trust document or a brief summary of the trust provisions shoul= be attached to the 709 if there are any trust gifts reported. I ha=en't seen the IRS question the absence of this; but technically, t=e gift has not been "adequately disclosed" without this attachment, meaning that the statute of limitations never beg=ns to run on the return. please no=e EFTA_R1_01895844 EFTA02652537