To: Jeffrey EpsteinBeeyacation©gmail.com] From: Richard Joslin Sent: Thur 3/13/2014 10:53:10 AM Subject: question Regretably, my answer was correct. The sale is the taxing event not the cash flow or gain recognition. I will look to see if any changes since 2003. see link below http://www.tax.ny.gov/pdf/advisory_opinions/sales/a03_85.pdf EFTA_R1_00387324 EFTA01933803