understood, but is the calculation every year that of an i=stallment obligation or does it reflect the specific character of
the t=x saved by apo? ie, the mix of tax savings or the mix of original sale =/div>
On Wed, May 1=, 2013 at 8:40 AM, Fenn, Patrick mailto > wrot=:
Gain on sale would be a combination of capital gain and ordinary income. Th= sale of the installment obligation
is considered to be an amount realized=on the sale of the property giving rise to the installment obligation. So = sale of
the TRA would be taxed as part ordinary and part capital gain in the same proportion as applies t= the original sale of the
partnership interest that gave rise to the insta=lment sale. Will get to Vincent today about the calculation.
From: Jeffrey Epstein (mailto:jeevacation@gmail.com <mailto:jeevacat=on@gmail.com>
Sent: Wednesday, May 15, 2013 08:32 AM
To: Fenn, Patrick
Subject:
IF i understood you correctly, I assume the sale or exchan=e of the the remaining tra payments would be
considered disposition of =nstallment debt so mostly Itcg. After vincent calculates the amount, we=should talk.
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