EFTA01122861Set 9
33p13,452w
optimistic about art owners' ability to defer income taxation by engaging in
like-kind exchanges of artworks that have appreciated in value. The keys to successfully
achieving this objective ... F.2d
1316)(1970).
a See, e.g., Wierbicki, "Like-Kind Exchanges." Trusts & Estates, May 2013, at p. 41.
By Lou Weller, Of Counsel, San Francisco, CA,
www.bryancave.com A Broader Perspective
America
https://www.justice.gov/epstein/files/DataSet%209/EFTA01122861.pdf
EFTA01071851Set 9
2011-08-3186p39,521w
Internal Revenue Code of 1986, as
amended, in order to effect a like-kind exchange within the meaning of said Section 1031 (the "Like-Kind
Exchange").
C. In connection with ... Like-Kind Exchange, (i) EAT, as lessor ("Lessors) and Owner
Trustee, as lessee ("Lessee') are entering into an Aircraft Dry Lease dated as of August 31, 2011 (as
amended, amended ... Internal Revenue Code of 1986, as amended, in order to
effect a like-kind exchange within the meaning of said Section 1031 (the "Like-Kind Exchange").
C. Avioneta and Owner
https://www.justice.gov/epstein/files/DataSet%209/EFTA01071851.pdf
EFTA01070351Set 9
2011-08-3143p24,061w
Internal Revenue Code of 1986, as amended, in order to
effect a like-kind exchange within the meaning of said Section 1031 (the "Like-Kind Exchange").
C. Avioneta and Owner ... finance the purchase by EAT of the Aircraft in order to facilitate the Like-Kind Exchange and to
finance certain refurbishments and upgrades to the Aircraft. Contemporaneously herewith, Owner Trustee ... N12NZ and
manufacturer's serial number 1376 (the "Existing Aircraft"). To complete the Like-Kind Exchange, Avioneta
intends to instruct Existing Owner to enter into a contract to sell
https://www.justice.gov/epstein/files/DataSet%209/EFTA01070351.pdf
EFTA01073799Set 9
2011-08-3181p38,222w
Internal Revenue Code of 1986, as amended, in order to
effect a like-kind exchange within the meaning of said Section 1031 (the "Like-Kind Exchange").
C. Avioneta and Owner ... finance the purchase by EAT of the Aircraft in order to facilitate the Like-Kind Exchange and to
finance certain refurbishments and upgrades to the Aircraft. Contemporaneously herewith, Owner Trustee ... Mark N12NZ and
manufacturers serial number 1376 (the "Existing Aircraft). To complete the Like-Kind Exchange, Avioneta
intends to instruct Existing Owner to enter into a contract to sell
https://www.justice.gov/epstein/files/DataSet%209/EFTA01073799.pdf
EFTA01222716Set 9
2p1,198w
line 26 or 37 4
5 Section 1231 gain or (loss) from like-kind exchanges from Form 8824 5
6 Gain, if any, from line 32. from other than casualty ... Form 6252, line 25 or 36 15
16 Ordinary gain or (loss) from like-kind exchanges from Form 8824 16
17 Combine lines 10 through
https://www.justice.gov/epstein/files/DataSet%209/EFTA01222716.pdf
EFTA01222714Set 9
2p1,224w
line 26 or 37 4
5 Section 1231 gain or (loss) from like-kind exchanges from Form 8824 5
6 Gain, if any, from line 32. from other than casualty ... Form 6252, line 25 or 36 16
16 Ordinary gain or (loss) from like-kind exchanges from Form 8824 16
17 Combine lines 10 through
https://www.justice.gov/epstein/files/DataSet%209/EFTA01222714.pdf
EFTA01128223Set 9
2012-07-1024p7,553w
Form 8824. Black represents that it will prepare and file IRS Form 8824,
Like-Kind Exchanges, or an equivalent statement, and, upon request, will furnish the Company
with a copy
https://www.justice.gov/epstein/files/DataSet%209/EFTA01128223.pdf