EFTA01106843Set 9
2013-06-1717p7,366w
Trust7 =
Trust8 =
Trust9 =
Trust10 =
Date =
n1 =
n2 =
n3 =
n4 =
n5 =
n6 =
n7 =
n8 =
n9 =
n10 =
ISSUES
1) Whether grantor trusts are disregarded as entities separate from their owners ... which mostly went to A), A should be treated as
owning more than n10 percent of the LLC. Under the attribution rules of § 267, B, C,
and D would then ... each be treated as owning more than n10 percent of the LLC (in
addition to the portion they own directly).
Examination also takes the position that, because the Purchasing Trusts
https://www.justice.gov/epstein/files/DataSet%209/EFTA01106843.pdf
EFTA00129298Set 9
2019-07-0614p2,875w
APPLE,IPHONEX
279,07/22/19 13:29:19,0:08,0:0 35940908147858,310410662903025,MT,(N10
P] APPLE,IPHONEX
280,07/22/19 15:23:26,0:22,0:0 ,,ST,(NIOP ... APPLE,IPHONEX
294,07/22/19 22:31:39,0:00,0:00 35940908147858,310410662903025,MT,(N10
P] APPLE,IPHONEX
295,07/22/19
https://www.justice.gov/epstein/files/DataSet%209/EFTA00129298.pdf
EFTA00801558Set 9
5p1,581w
I4244 .4.4022144,401044.44,4
• $00/WhOslurt!•Piatk7 0140
0 11
I107 1,1**N10 NM INNEN, 4a
WAS 'Mond= lo tot Kam Won
lap Widow to Ina AN. Doer
'Cl MUlkor
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801558.pdf