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Re: LDB 2011 LLC Restructuring

1 message picture_as_pdf Source PDF
J
jeevacation@gmail.com Jun 13, 2014 5:43 PM
To
Ada Clapp

same issue, i would Ike brad okun or fenn to opine on these notes

On Fri, Jun 13, 2014 at 1:03 PM, Ada Clapp wrote:

Hi Jeffrey,

Hope that you are having a good day.

Attached are the sale documents in connection with the LDB restructuring. At our last meeting, you indicated that you wanted to review them. As a reminder, each of the children's 2011 Trusts will sell its one-fourth interest in the restructured LDB 2011 LLC to the APOI Trustees in exchange for a note (purchase price to be determined by appraisal). The attached are for a sale between Ben's 2011 Trust and the APOI Agreement. They will be "cloned" for the other children's trusts. We are set up for a June sale and I await your comments on these documents before circulating for signature.

Best regards,

Ada Clapp

Elysium Management LLC

445 Park Avenue

Suite 1401

New York, New York 10022

Direct Dial: 646-589-0303

Fax: 646-589-0330

Email:

IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used, by any person or entity for the purposes of (i) avoiding tax related penalties imposed by any governmental tax

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authority, or (ii) proposing, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances.

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