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EFTA02667860

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EFTA02667860

From: Bodian, Robert Sent: Sunday, December 11, 2016 9:14 AM To: Halperin, Alan S Cc: Fenn, Patrick Subject: Re: Quick call re the Josh tax letter The subject of the call will be the statement that Taxpayers are not under civil or criminal investigation

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dossier finding_evidence Finding #13155

Brad Karp

Subject: Fw: Quick call re the Josh tax letter Fyi, Jeffrey. Several weeks ago, the IRS agreed that it would close the audit of the 2014 gift tax return with no change on the return. The IRS wants a modest increase to the value of the interests transferred to the GRATs, which results in increased annuity flows to Josh.

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Dechert LLP

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Dechert LLP

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Joshua Harris