From: Ellen Harrison
To: Jeffrey Epstein <jeevacation@gmail.com>
Subject: Re: M
Date: Mon, 13 Jan 2014 14:37:11 +0000
I don't follow your email. The purchase price for the debt should not exceed the value of the company without
counting the debt.
If debt exceeds equity then the equity has no value.
After I speak with my tax people, I will let you know their view of what your proposal to purchase the debt
would accomplish.
Unfortunately the insolvency exceptions to forgiveness of debt don't work for a partnership if the partner is
solvent.
Sent from my iPhone
On Jan 13, 2014, at 9:23 AM, Jeffrey Epstein <jeevacation@gmail.com> wrote:
all understood, but i dont see it on sale. ? what is the basis in the equity? If the debt were to be bought for
roughtly the same amount as the equity, . eventually , the debt would receive the prefenrence giving the holder
enough money to pay off the equity, . ( potential gain issues.? ) . I would thihnk an eventual bankruptcy .
could be a solution , after his death,
On Mon, Jan 13, 2014 at 10:20 AM, Ellen Harrison < > wrote:
COD is first at the entity level but is allocable to Mort.
As to when - many possibilities. Substantial modification of debt, actual forgiveness, contribution of the debt
to the company, transfer of Mort's interest, to name a few.
Sent from my iPhone
On Jan 13, 2014, at 8:51 AM, Jeffrey Epstein <jeevacation@gmail.com> wrote:
where and when is the COD?
On Mon, Jan 13, 2014 at 9:25 AM, Ellen Harrison < > wrote:
On your question about Mort's basis in the notes, I checked with Brian and He said the notes had not been
written down so I gave you bad information. Sony.
In my opinion, your purchase of the receivables from Mon would not cure the COD issue we are worried
about. Even if the sale generated a capital loss, that would not offset ordinary income from COD.
However, we will continue to explore this along with other ideas
My partner is working on an accounting for the 1983 and 1996 trusts. She is still getting data. This has
been in process for less than a month. I expect that it will be some time before it is done because I am
told that the records prior to 2000 are limited.
SRR is appraising R&R. We are hoping, of course, that the cash flow will be sufficient to cover the
preference. Since we don't have the appraisal or the preference yet we don't know whether this will be a
EFTA00689472
problem. If it is, I would use debt to reduce value so cash flow would cover the preference. This is a
problem under section 2701, because the common has to equal 10% of enterprise value before debt, but
we will figure it out.
Sent from my iPhone
On Jan 13, 2014, at 7:19 AM, Jeffrey Epstein lea@gmail.com> wrote:
EH you told me that morts basis in the 12 percent notes had been written down, can you explain, .
can you tell me the status of the trust accounting to date. ? you stated that Rand R was being valued,
and planned to put it in a preferred partnership. ? what is the plan if the cashflow is not enough to pay
the preferred. ?
On Sun, Jan 12, 2014 at 2:30 PM, Ellen Harrison <I > wrote:
> Hello
> I just left you a voicemail. I would like to speak with you briefly about the terms of the deal you
ro sed to MZ so that we can give it appropriate analysis. Could you please give me a call at
or reply to this email as soon as possible? We are trying to schedule a conference call with
tax advisors on Monday between 10 and 12 and it would be very helpful to have your proposal in
hand by then.
> Thanks and Happy New Year.
> Sent from my iPhone
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The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
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communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in en-or, please notify us immediately by
return e-mail or by e-mail to jeevacation@gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jea@gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
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