EFTA02438945.pdf

To: Rabia Cc: Joel Bofffj From: Kathleen Buzbee Sent: Tue 4/7/2009 9:22:42 PM Subject: RE: Tax Returns et al Daniel I have been tied up all day on a major project that has to go tomorrow am. Based on your (Jennie's) assurance that you were and are still a personal guarantor of the debt, I will overnight the 2005 NY amended return to you tomorrow. As long as the basis created by this guarantee still exists, then I do not have any professional concerns with issuing the 2005 amended return. Your 2008 personal returns were put on extension. Unless one of you needs to share any info that would directly impact the 2005 amended return, I think that this tele-con can wait until after Apr 15th. Kathleen F. Buzbee CPA/ABV, CVA, MST Principal Konowitz, Kahn s Company, P.C. 127 Washington Ave North H ve C 06 72- 9 Phone: Fax: Any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. PRIVILEGED AND CONFIDENTIAL: This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential or privileged information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email and delete this communication and destroy all copies. From: Jennie Saunders [mailto: Sent: Tuesday, April 07, 2009 5:12 PM To: Daniel Rabia; Kathleen Buzbee Cc: Joel Boff Subject: RE: Tax Returns et al Kathy -PLEASE let us know when u can speak ---as you mentioned there is a deadline to file for the refund and we feel confident that we have everything u need .... EFTA_R1_01512519 EFTA02438945 CORE: Jennie Saunders I President and Chief Executive Officer 66 East 55th Street New York NY 10022 I Main: <http://www.coreaccess.net/> www.coreaccess.net I This message and any attachments, may contain confidential and/or legally privileged information. If you are not the intended recipient of the message by the original sender, please destroy it. Message and attachments copyright O 2008, all rights reserved. Any unauthorized dissemination, distribution or copying is strictly forbidden. From: Daniel Rabia Sent: Tuesday, April 07, 2009 11:38 AM To: 'Kathleen Buzbee' Cc: Jennie Saunders: 'Joel Boff' Subject: RE: Tax Returns et al Hi Kathy, Jennie would like to join us on this call as well. Could you please advise as to your earliest availability? Thanks, Daniel CORE: I Daniel Rabia I Chief Financial Officer' 66 East 55th Street, New York NY 10022 Id: 78011www. From: Daniel Rabia Sent: Monday, April 06, 2009 5:34 PM To: Kathleen Buzbee Cc: 'Joel Boff' Subject: RE: Tax Returns et al Kathy, EFTA_R1_01512520 EFTA02438946 We just completed the call and I was hoping you are available for a conference call tomorrow morning with our tax preparer and I as we want to make sure we have all the facts straight so we can give you what you need to file Jennie's return. We will provide a dial in number for the call. Please advise as to your availability. Kind Regards, Daniel CORE: I Daniel Rabia I Chief Financial Officer' 66 East 55th Street, New York NY 10022 Id: 7801Iwww.coreaccess.net From: Kathleen Buzbee [mailto Sent: Monday, April 06, 2009 To: Daniel Rabia Subject: RE: Tax Returns et al The return preparer of the partnership return is responsible for allocating the liabilities properly Kathleen F. Buzbee CPA/ABV, CVA, MST Principal Konowitz, Kahn & Company, P.C. 127 Washington Ave North Haven, CT 06473-0190 Phone: Fax: Any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. PRIVILEGED AND CONFIDENTIAL: This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential or privileged information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email and delete this communication and destroy all copies. EFTA_R1_01512521 EFTA02438947 From: Daniel Rabia [mailto: Sent: Monday, April 06, 2009 3:23 PM To: 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 or can you allocate her proportionate share from the K-1 from TCCI to TCGM? CORE: I Daniel Rabia I Chief Financial Officer' 66 East 55th Street, New York NY 10022 Id: IIIIIwww.coreaccess.net From: Kathleen Buzbee [mailto: Sent: Monday, April 06, 2009 31.11 To: Daniel Rabia Subject: RE: Tax Returns et al Because Jennie is (was?) the managing member of the LLC's and had personally guaranteed loans, the debts were allocated to her K-1 in 2005 which then created basis for her to take the losses. The losses created a net operating loss in her return which allowed her to file a claim for refund of previous taxes paid. The timing issue comes as follows- if, in the future, the Club reaches the point when it makes income it will be allocated to Jenny until it offsets all losses previously allocated to her. This income is then included in her personal return in the year received, and can then be offset by the normal itemized deductions. Kathleen F. Buzbee CPA/ABV, CVA, MST Principal Konowitz, Kahn & Company, P.C. 127 Washington Ave North Haven, CT 06473-0190 Phone: Any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. PRIVILEGED AND CONFIDENTIAL: This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential or privileged information. If you are not the intended recipient, any use, copying, EFTA_R1_01512522 EFTA02438948 disclosure, dissemination or distribution is strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email and delete this communication and destroy all copies. From: Daniel Rabia (mailto Sent: Monday, April 06, 2009 3:04 PM To: Kathleen Buzbee Cc: Jennie Saunders Subject: Tax Returns et al Hi Kathy, Jennie has asked me to follow up with you re your e-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 that is where the PG's actually reside. In the K-1's we sent you we only included the K-1's in Jennie's name based on a call you and I had several weeks ago. One item we need clarity on is with regard to the following statement in your e- mail to Jennie: "I also had warned you many times that this refund was due to timing and that some day you would have to return it." What is the meaning of having to return the refund one day? Under what circumstances does the refund have to be returned? We have a call at 5pm to discuss with our tax preparer the open issues you have raised and would be great to know the answer to the above beforehand. I will forward a summary of the call to you and we can them determine if you are more comfortable filling Jennie's return as there is no material change other than ownership changes that took place in 2006. EFTA_R1_01512523 EFTA02438949 Thanks, Daniel CORE: I Daniel Rabia I Chief Financial Officerl 66 East 55th Street, New York NY Id: www.coreaccess.net DISCLAIMER Important! This message is intended for the above named person(s) only and is CONFIDENTIAL AND PROPRIETARY. If you are not the intended recipient of this e-mail and have received it in error, please forward to ITsupport@coreaccess.net with 'Received in Error' as the subject and then delete it from your mailbox. Accessing, copying or re-using any of the information contained in this e-mail by anyone other than the intended recipient is unauthorized. Thank you. Any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. PRIVILEGED AND CONFIDENTIAL: This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential or privileged information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email and delete this communication and destroy all copies. DISCLAIMER Important! This message is intended for the above named person(s) only and is CONFIDENTIAL AND PROPRIETARY. If you are not the intended recipient of this e-mail and have received it in error, please forward to ITsupport@coreaccess.net with 'Received in Error' as the subject and then delete it from your mailbox. Accessing, copying or re-using any of the information contained in this e-mail by anyone other than the intended recipient is unauthorized. Thank you. Any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. PRIVILEGED AND CONFIDENTIAL: This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential or privileged information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email and delete this communication and destroy all copies. DISCLAIMER Important! This message is intended for the above named person(s) only and is CONFIDENTIAL AND PROPRIETARY. If you are not the intended recipient of this e-mail and have received it in error, please forward to ITsupport@coreaccess.net with 'Received in Error' as the subject and then delete it from your mailbox. EFTA_R1_01512524 EFTA02438950 Accessing, copying or re-using any of the information contained in this e-mail by anyone other than the intended recipient is unauthorized. Thank you. Any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the United States Internal Revenue Code or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. PRIVILEGED AND CONFIDENTIAL: This communication, including attachments, is for the exclusive use of addressee and may contain proprietary, confidential or privileged information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email and delete this communication and destroy all copies. EFTA_R1_01512525 EFTA02438951