Epstein Files Search

EFTA01122861Dataset 9

33p13,452w

…be a secondary intent of the acquisition and ownership. In the real estate context, this question most often arises with vacation use properties. In this category, the most important factor determining Code Sec. 1031 qualification seems to be the degree of effort (and success) spent in renting a property compared to the amount of personal use" As with real estate, there are various strategic and operational measures that indicate investment intent relating to artworks. Since artworks generally are not depreciable…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01122861.pdf

EFTA01142002Dataset 9

2013-09-184p913w

Subject: Re: PRO-FORMA TAX TREATMENT - AIRCRAFT OPERATION

From: Thomas TurrinTo: Jeffrey Epstein <[email protected]>

…personal use) is subject to 7.5% US excise tax (per discussion with Pat Fenn at Akin Gump and based on my own research). I calculated the loss using bonus depreciation (50%) and without bonus depreciation. The operation of the aircraft would be characterized as a passive activity on Leon's return. Leon would not be able to claim that he is materially participating in an active trade or business with respect to the aircraft operation (IRC Code Sec 469)…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01142002.pdf

EFTA00598048Dataset 9

2009-08-138p5,377w

…IRS Letter Ruling 200945069 (Aug. 13, 2009), Internal Revenue Service, (Aug. 13, 2009) Click to open document in a browser LTR 200945069, August 13, 2009 Symbol: Not Given Uniform Issue List No. 0501.03-00 [Code Sec. 5011 Exception from tax on corporations, certain trusts, etc. (Exempt v. not exempt); Religious, charitable etc. Institutions and community chest This is our final determination that you do not qualify for exemption from Federal income tax as an organization described in Internal Revenue…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00598048.pdf

EFTA01141973Dataset 9

2013-09-174p900w

Subject: Fwd: PRO-FORMA TAX TREATMENT - AIRCRAFT OPERATION

From: Jeffrey Epstein <[email protected]>To: Melanie Spinella

…personal use) is subject to 7.5% US excise tax (per discussion with Pat Fenn at Akin Gump and based on my own research). I calculated the loss using bonus depreciation (50%) and without bonus depreciation. The operation of the aircraft would be characterized as a passive activity on Leon's return. Leon would not be able to claim that he is materially participating in an active trade or business with respect to the aircraft operation (IRC Code Sec 469)…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01141973.pdf

EFTA00598071Dataset 9

2002-11-2712p8,068w

…T.C. Memo. 2002-293, 84 TCM 586, Filed November 27, 2002. [Appealable, barring stipulation to the contrary, to CA-6.—CCH.] [ Code Sec. 509] Private foundation defined: Supporting organizations: Integral part test.).— P is a nonprofit corporation described In sec. 501(c)(3), I.R.C., and exempt from taxation under sec. 501(a), I.R.C. ■ articles of incorporation, as flied in conjunction with its application for exempt status, provide that it is to operate exclusively for…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00598071.pdf

EFTA01141959Dataset 9

2013-09-172p634w

Subject: PRO-FORMA TAX TREATMENT - AIRCRAFT OPERATION

From: Thomas TurrinTo: Jeffrey Epstein <[email protected]>

…personal use) is subject to 7.5% US excise tax (per discussion with Pat Fenn at Akin Gump and based on my own research). I calculated the loss using bonus depreciation (50%) and without bonus depreciation. The operation of the aircraft would be characterized as a passive activity on Leon's return. Leon would not be able to claim that he is materially participating in an active trade or business with respect to the aircraft operation (IRC Code Sec 469)…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01141959.pdf

EFTA00597073Dataset 9

2p446w

…IRC Sec(s). 267 Headnote: Rev. Rul. 59-171, 1959-1 CB 65 -- IRC Sec. 267 Reference(s): Code Sec. 267; Reg § 1.267(b)-1 Where two persons are trustees of separate trusts of a common grantor, deductions for losses sustained on the purchase and sale of securities between the trustees in their capacity as individuals rather than in their capacity as fiduciaries, are not prohibited by 1.1 section 267 of the Internal Revenue Code of 1954. Full…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00597073.pdf

EFTA00598317Dataset 9

2010-12-311p537w

…Any amount in excess of the percentage limitation for the tax year may be carried forward for a period of five years (¶1060) ( Code Sec. 170(d)). 156 When spouses file a joint return, the percentage limitation depends on their aggregate contribution base ( Reg. §1.170A-8(a)). 1.51 A limit also applies to the amount of a charitable deduction allowed for gifts of appreciated property ( ¶1062), and is imposed before applying the percentage limitation ( Code Sec. 170(e)…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00598317.pdf

EFTA01145923Dataset 9

2012-10-252p439w

Subject: Tr : booking terms

From: Jean Luc BrunelTo: [email protected]" .cjecvacationgsmail.com>

…Faena, not endorsing Faena. Please note that license to use photographs or images shall not be deemed granted until full payment for the photo shoot and any additional agreed upon usages arc received by MC2. Under Fla. Stat. Sec. 540.08 and New York Civil Code Sec. 50 & 51, and other state and common laws, the right of publicity remains with the person whose imagc is portrayed, until express consent is obtained. ' CA St Agent Signature ate Faena Rep. Signature…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01145923.pdf

EFTA01145925Dataset 9

1p331w

…on behalf of Faena, not endorsing Faena. Please note that license to use photographs or images shall not be deemed granted until full payment for the photo shoot and any additional agreed upon usages are received by MC2. Under Fla. Stat. Sec. 540.08 and New York Civil Code Sec. 50 & 51, and other state and common laws, the right of publicity remains with the person whose image is portrayed, until express consent is obtained. agent signature Faena Rep. Signature …

https://www.justice.gov/epstein/files/DataSet%209/EFTA01145925.pdf

EFTA01116950Dataset 9

2p446w

…IRC Sec(s). 267 Headnote: Rev. Rul. 59-171, 1959-1 CB 65 -- IRC Sec. 267 Reference(s): Code Sec. 267; Reg § 1.267(b)-1 Where two persons are trustees of separate trusts of a common grantor, deductions for losses sustained on the purchase and sale of securities between the trustees in their capacity as individuals rather than in their capacity as fiduciaries, are not prohibited by 1.1 section 267 of the Internal Revenue Code of 1954. Full…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01116950.pdf

EFTA01141968Dataset 9

2013-09-173p805w

Subject: RE: PRO-FORMA TAX TREATMENT - AIRCRAFT OPERATION

From: Thomas TurrinTo: Jeffrey Epstein <[email protected]>

…personal use) is subject to 7.5% US excise tax (per discussion with Pat Fenn at Akin Gump and based on my own research). I calculated the loss using bonus depreciation (50%) and without bonus depreciation. The operation of the aircraft would be characterized as a passive activity on Leon's return. Leon would not be able to claim that he is materially participating in an active trade or business with respect to the aircraft operation (IRC Code Sec 469)…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01141968.pdf

EFTA01141876Dataset 9

2013-09-263p763w

Subject: Fwd: PRO-FORMA TAX TREATMENT - AIRCRAFT OPERATION

From: Jeffrey Epstein <[email protected]>To: Melanie Spinella

…personal use) is subject to 7.5% US excise tax (per discussion with Pat Fenn at Akin Gump and based on my own research). I calculated the loss using bonus depreciation (50%) and without bonus depreciation. The operation of the aircraft would be characterized as a passive activity on Leon's return. Leon would not be able to claim that he is materially participating in an active trade or business with respect to the aircraft operation (IRC Code Sec 469)…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01141876.pdf

EFTA01118520Dataset 9

4p3,163w

…By execution of this Subscription Agreement, the Investor agrees that it shall be deemed to have executed the Limited Partnership Agreement. 4 EFTA01118521 Nontaxable exchanges Code Sec. 1031(a)(1) 1963. of a corporative which was a foreign mental Padang in most recent uutabk yeas ending before the date of the company for In 1964. redesignated Code Sec. 1022 at Code Sec. 1023. decedette s death . stall be iceatased by its ptOpanionate sham Of ay Federal cute tat atrib- PART…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01118520.pdf

EFTA01199338Dataset 9

2000-11-174p1,224w

…2/23/2001, IRC Sec(s). 170 UIL No. 170.12-03 Headnote: Under Code Sec. 170; , shareholders donation of stock, that is subject to voting agreement which requires shareholder to vote as directed by another individual, is deductible. Reference(s): Code Sec. 170; Full Text: Release Date: 2/23/2001 Date: November 17, 2000 Refer Reply To: CC:IT&A:3-PLR-122379-00 LEGEND: Taxpayer = Individual = Company = "' Foundation = "" Dear "' EFTA01199338 This is in reply…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01199338.pdf

EFTA01141935Dataset 9

2013-09-273p758w

Subject: Fwd: PRO-FORMA TAX TREATMENT - AIRCRAFT OPERATION

From: Jeffrey Epstein <[email protected]>To: Eileen Alexanderson , Melanie Spinella

…personal use) is subject to 7.5% US excise tax (per discussion with Pat Fenn at Akin Gump and based on my own research). I calculated the loss using bonus depreciation (50%) and without bonus depreciation. The operation of the aircraft would be characterized as a passive activity on Leon's return. Leon would not be able to claim that he is materially participating in an active trade or business with respect to the aircraft operation (IRC Code Sec 469)…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01141935.pdf

EFTA01958543Dataset 10

2013-08-261p125w

To: Mortimer Zuckerman(mzuckerman©bostonproperties.com] Fran: Jeffrey Epstein Sent Mon 8/26/2013 8:13:13 PM ):ST OF MARINE v COMM 71 AFTR 2d 93 2182 990 F 2d 136 Code Sec s 2055 CA4 03_30_1993(1).pdf the case i referenced *********************************************************** 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…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01958543.pdf

EFTA00598316Dataset 9

2011-07-281p681w

…taxes ( ¶647). An excise tax is also imposed if a donor advised fund makes a distribution to any person that results in (directly or indirectly) a more-than-incidental benefit to the donor, donor advisor, member of the donor's family, or any entity in which the donor holds more than a 35-percent ownership interest ( Code Sec. 4967). 27 The tax is 125 percent of the benefit received and is imposed on the donor, donor advisor, and related persons…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00598316.pdf

EFTA00584985Dataset 9

2011-11-2211p3,318w

Checkpoint Contents Federal Library Federal Source Materials IRS Rulings & Releases Private Letter Rulings & TAMs, FSAs, SCAs, CCAs, GCMs, AODs & Other FOIA Documents Chief Counsel Advice 2012 CCA 201210026 -- Code Sec(s). 4261, 03/09/2012 CCA 201210026 UIL No. 4261.00-00Excise taxes—transportation of persons by air—aircraft management fees. Headnote: Control of aircraft's pilots is factor for determining person who has possession, command and control of aircraft, and management has possession, command and control of aircraft in…

https://www.justice.gov/epstein/files/DataSet%209/EFTA00584985.pdf

EFTA01142269Dataset 9

2013-08-261p114w

From: Jeffrey Epstein <[email protected]>To: Mortimer Zuckerman

From: Jeffrey Epstein <[email protected]> To: Mortimer Zuckerman Subject: Date: Mon, 26 Aug 2013 20:13:13 +0000 Attachments: ESTOF_MARINEv_COMM 71AFTR_2c1_93_2182_9903_2d_136 Code_Sec _s_2055 CA4 _03_30_1993(1).pdf the case i referenced 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…

https://www.justice.gov/epstein/files/DataSet%209/EFTA01142269.pdf