Epstein Files Search

EFTA02038146Set 10

2013-03-3022p6,774w

Rule o Issue: Effect of IRC section 704(c) On Partners' Share of Non- Recourse Liabilities o Issue; "Reverse" 704(c) — Revaluations o Examination Techniques o Supporting Law o Resources ... context of amortizable property • Impact ofIRC section 704(c) on the sharing of non-recourse liabilities • "Reverse" IRC section 704(c) which addresses re-valuations • IRC section ... ISSUE: EFFECT OF IRC SECTION 704(c) ON PARTNERS' SHARE OF NON- RECOURSE LIABILITIES As was discussed in Chapter I, a partner's share of non-recourse liabilities

https://www.justice.gov/epstein/files/DataSet%2010/EFTA02038146.pdf

EFTA00692346Set 9

2013-03-3014p6,650w

Rule o Issue: Effect of IRC section 704(c) On Partners' Share of Non-Recourse Liabilities o Issue: "Reverse" 704(c) — Revaluations o Examination Techniques o Supporting Law o Resources ... context of amortizable property • Impact ofIRC section 704(c) on the sharing of non-recourse liabilities • "Reverse" IRC section 704(c) which addresses re-valuations • IRC section ... ISSUE: EFFECT OF IRC SECTION 704(c) ON PARTNERS' SHARE OF NON-RECOURSE LIABILITIES As was discussed in Chapter I, a partner's share of non-recourse liabilities

https://www.justice.gov/epstein/files/DataSet%209/EFTA00692346.pdf

EFTA01154591Set 9

2014-04-3055p15,833w

time, for example, 12 months. 8. Partner's Share of Partnership Liabilities A. Recourse Liabilities I6 EFTA01154606 taxanalysts DOCUMENT SERVICE Doc 2014 1995 (SS pgs) The existing regulations under section ... amended by: a. Removing the language "or would be treated as a recourse liability under that section if it were treated as a partnership liability for purposes of that section ... corresponding regulations, the $20,000 liability incurred on September 13, 2014, is a recourse liability of KL and K's share of that liability is $10,000 on November

https://www.justice.gov/epstein/files/DataSet%209/EFTA01154591.pdf

EFTA01097356Set 9

68p35,148w

from liability, but (ii) the sale or other disposition of property that secures a recourse liability discharges the transferor from the liability only if another person agrees ... Code § 752.75 Reg. § 1.752-1(a)(1) provides that "[a] partnership liability is a recourse liability to the extent that any partner or related person bears the economic risk

https://www.justice.gov/epstein/files/DataSet%209/EFTA01097356.pdf

EFTA00807082Set 9

8p2,536w

Beginning 0.03708 Ending 0.03708 32. Percentage ot capital Beginning 0.03708 Ending 0.03708 33. Non-recourse liabilities Ending 34. Qualified non-recourse financing Ending 35. Recourse liabilities Ending Pass-through Entity

https://www.justice.gov/epstein/files/DataSet%209/EFTA00807082.pdf

EFTA00805604Set 9

7p2,264w

Percentage ot capital Beginning 0 . 03560 Ending 0 . 03989 33. Non-recourse liabilities Wing 34. Qualified non-recourse financing Ending 35. Recourse liabilities Ending Pass-through Entity Payment and Credit

https://www.justice.gov/epstein/files/DataSet%209/EFTA00805604.pdf

EFTA01252686Set 9

2012-12-3122p9,337w

SUPPORTING SCHEDULES PARTNER It 1 == --------------- = ------------ =IM= ITEM K, PARTNER'S SHARE OF LIABILITIES RECOURSE LIABILITIES: ACCOUNTS PAYABLE 146,810. LONG-TERM MORTGAGES, NOTES AND BONDS PAYABLE 1,136,778. OTHER ... OTHER LIABILITIES: ACCRUED PROFIT SHARING 40,726. TOTAL OTHER LIABILITIES 40,726. TOTAL RECOURSE LIABILITIES 1,329,499. ITEM L - RECONCILIATION OF INCOME INCOME (LOSS) FROM SCH. K-1, LINES

https://www.justice.gov/epstein/files/DataSet%209/EFTA01252686.pdf

EFTA00771974Set 9

2009-10-237p2,276w

Kathleen Buzbee Subject: RE: Tax Returns et al Do the recourse liabilities need to be itemized on her K-1 in order for her to have basis ... mail to her from yesterday. It turns out that the recourse and non-recourse liabilities are itemized on the K-1 from TCCI to TCGM (The Core Group Management) since

https://www.justice.gov/epstein/files/DataSet%209/EFTA00771974.pdf

EFTA02438945Set 11

2009-04-077p1,876w

Kathleen Buzbee Subject: RE: Tax Returns et al Do the recourse liabilities need to be itemized on her K-1 in order for her to have basis ... mail to her from yesterday. It turns out that the recourse and non-recourse liabilities are itemized on the K- 1 from TCCI to TCGM (The Core Group Management) since

https://www.justice.gov/epstein/files/DataSet%2011/EFTA02438945.pdf

EFTA02438637Set 11

2009-10-239p2,551w

Kathleen Buzbee EFTA_R1_01511913 EFTA02438641 Subject: RE: Tax Returns et al Do the recourse liabilities need to be itemized on her K-I in order for her to have ... mail to her from yesterday. It turns out that the recourse and non-recourse liabilities are itemized on the K-I from TCCI to TCGM (The Core Group Management) since

https://www.justice.gov/epstein/files/DataSet%2011/EFTA02438637.pdf

EFTA00771966Set 9

2009-04-076p1,894w

Kathleen Buzbee Subject: RE: Tax Returns et al Do the recourse liabilities need to be itemized on her K-1 in order for her to have basis ... mail to her from yesterday. It turns out that the recourse and non-recourse liabilities are itemized on the K-1 from TCCI to TCGM (The Core Group Management) since

https://www.justice.gov/epstein/files/DataSet%209/EFTA00771966.pdf

EFTA00771981Set 9

2009-10-238p2,547w

Kathleen Buzbee Subject: RE: Tax Returns et al Do the recourse liabilities need to be itemized on her K-I in order for her to have basis ... mail to her from yesterday. It turns out that the recourse and non-recourse liabilities are itemized on the K-1 from TCCI to TCGM (The Core Group Management) since

https://www.justice.gov/epstein/files/DataSet%209/EFTA00771981.pdf

EFTA00741091Set 9

2009-10-238p2,201w

Kathleen Buzbee Subject: RE: Tax Returns et al Do the recourse liabilities need to be itemized on her K-1 in order for her to have basis ... mail to her from yesterday. It turns out that the recourse and non-recourse liabilities are itemized on the K-1 from TCCI to TCGM (The Core Group Management) since

https://www.justice.gov/epstein/files/DataSet%209/EFTA00741091.pdf

EFTA01822150Set 10

2009-04-079p2,204w

Kathleen Buzbee Subject: RE: Tax Returns et al Do the recourse liabilities need to be itemized on her K-1 in order for her to have basis ... mail to her from yesterday. It turns out that the recourse and non-recourse liabilities are itemized on the K-1 from TCCI to TCGM (The Core Group Management) since

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01822150.pdf

EFTA01280333Set 10

18p6,786w

Share of Nourecourse Liabilities at year-end 19 1,155 20 Panacea Share of Recourse Liabilities at year-end 20 L, 1207210053 1207210053 Partner # 316 CONFIDENTIAL SDNY_GM_00033310 EFTA ... Noorecourse Liabilities at year-end 17 1,155 18 Partner's Share of Recourse Liabilities at year-end 18 1207310051 1207310051 Partner*316 CONFIDENTIAL SDNY_GM_00033311 EFTA_00143924 EFTA01280350

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01280333.pdf

EFTA00797688Set 9

2017-07-18177p83,195w

AMENDED, RESTATED AND CONSOLIDATED LOAN AGREEMENT Dated as of July 18, 2017 By and Among

https://www.justice.gov/epstein/files/DataSet%209/EFTA00797688.pdf

EFTA02705481Set 11

2007-07-1312p4,960w

Regulations. in (i) a deemed distribution of Mr. Black's share of the non-recourse liabilities of AMH Holdings and (ii) the recognition of gain (what we have referred ... series of Section 754 elections described above, should include the amount of the non-recourse liabilities of AMH Holdings, such that the amount of any potential Tufts gain that would

https://www.justice.gov/epstein/files/DataSet%2011/EFTA02705481.pdf

EFTA00806988Set 9

16p7,568w

taken into account in computing Net Profits or Net Losses. (I) "Non recourse Liability" has the meaning set forth in Regulations Section 1.752-1(a)(2). (m) "Regulation(s)" means

https://www.justice.gov/epstein/files/DataSet%209/EFTA00806988.pdf