From: Richard Joslin Sent: Saturday, March 22, 2014 3:14 AM To: Jeffrey Epstein Subject: Re: Attachments: Untitled attachment 00222.pdf; Tax Deferred Exchanges of Art and Other Collectibles.pdf Re Loan and Re Disqualified QI A loan to a QI or Exchange Accomodation Titleholder is permitted in a =everse exchange based on Rev Proc 2000.37. <=font> .03 =ermissible Agreements. Property will not fail to be treated as being =eld in a QEAA as a result of any one or more of the following legal or con=ractual arrangements, regardless of whether such arrangements contain term= that typically would result from arm's length bargaining between un=elated parties with respect to such arrangements:\ (1) An exchange accommodation titleholder that satisfies the requireme=ts of the qualified intermediary safe harbor set forth in §1.1031(k)&nda=h;1(g)(4) may enter into an exchange agreement with the taxpayer to serve =s the qualified intermediary in a simultaneous or deferred exchange of the=property under § 1031; (2) The taxpayer or a disqualified person guarantees some=or all of the obligations of the exchange accommodation titleholder, inclu=ing secured or unsecured debt incurred to acquire the property, or indemni=ies the exchange accommodation titleholder against costs and expenses; (3) The taxpayer or a disqualified person loans or advanc=s funds to the exchange accommodation titleholder or guarantees a loan or =dvance to the exchangeaccommodation titleholder; Re Disqualifed O1 I am looking to see if Gagosian transacted with Blacks within 2 year w=ndow. The Bryan Cave article references the Weirbicki article a=d expands analysis http://www.bryancave.com/files/Publication/8e2abb2a-1093-490f=a190- 0cec7496697e/Presentation/PublicationAttachment/961d6f73-1c5c-43cb-88=6- 1295b5942efd/Tax%20News%20and%20Developments%20(Fall%202013).pdf <http://www.bryancave.com/files/Publication/8e2abb2a-1093.49=f-af90- 0cec7496697e/Presentation/PublicationAttachment/961d6f7