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The following is alist of things I think would be in your interest to get done asap .but definitely not by me.
isuggest you form new grats. , hire a high level tax partner. use your trading accounts as they remain
the paramount requirement 16 months after 1 emailed to you their importance. , I suggest you
consider having the 49percent of phaidon merged into artspance and have Richard buy artspace. re-do bank
loans. no need to pay interest at higher rates on boat or plane. . as Richard is now no longer trustee. re- do
will, make suydam executor , with Barry, and john as back up. pay 1 million a year for executor role. get rid
of Judy Black trust, deal with gifts and their tax returns, . review amounts to kids at fixed ages. put more
protections in for Alex and Victoria. , distribute some money to kids let them make decisions. , decide art
division with children in attendance . have fire drill done on estate. fill out estate returns as if you and Debra
died today, choose advisers - rick bronstein said the only 1040 he ever filled out was his own. ( this is brads
chosen advisor??!) Halperin has a conflict that should be addressed., Debra should enter a tenants in common
agreement with kids. you have airplane consultants tax consultants it consultants. plane operation consultant.
. boat consultants. architects, lighting , art, legal, . foundation , deal with TRA , BRH, rationalize
investments. cash flow. reporting, gaming disclosures. foreign, gift. . prepare tax projections for 15 and 16, .
deal with neg basis ( tufts gain, debt financed. art partnership, pledges. sell stock , art, deal with phaidon
debt. athene,? income, capital , foreign , exit, corporate, insurance regs, out and inbound
issues, basis, appropriate discount rates. ? terminations. control. , qualified dividends. corporate
tolls, inversion rules. , grat issues, short swing and other sec disclosures, Rothshcild bank, 150b they have a
distribution network with no products , private bank Rockefeller Rothschild. financial service. deal with UK
visa issue sooner rather than later. we can talk about Rowen request re Athene , 2 billion in taxes on
transaction. ?!
the facts as i see them
in June and then again Sept, we both agreed to a 50% of phaidon payout., then after weeks of thinking about
the issue ( which I fully understand ) . the payout was unilaterally changed . 5m woudl be reserved for the
future ? . and out of the remaining 15m ,? i would receive only 5. ( note : I'm confident that both the debt , and
the artspace investment will also lead to a write off of another 30 m. plus ) In my dining room ,you were
surprised when I said that i require most people to pay their advisory fee up front so that I am assured that I
will be properly compensated for my work when strategies that I devise are implemented . you may recall that
you appeared offended and said " are you suggesting that i would go back on my word " J said no , of course
not ! you are my closest of friends ,but my experience is that when amounts get large, people tend to get
unhappy when it actually comes time for them to pay ,.
From day zero a 50 - 60 million price was attached as the fair price of the transaction just completed .
though this amount was already substantially less thanour agreed and negotiated formula. - I was
never told that this was out of range. in fact, alternative methods of payment. plane -in-kind etc, were
discussed (ie keeping the 30m portion of fee outstanding till March ) ,I provided as requested a
detailed step by step execution plan and reviewed all documents that i was given access to. ( Phaidon was not
forthcoming ) in order to make my many corrections. I was then told that Alans involvement warranted a
discount. Even in the best of light , though it is beyond question that not one-,not -one time in three
years has he ever proposed a unique idea. (including the new tenant in common idea,) and lets say he made
a contribution to the plan andeven that it was 50 %. though no one could posit such a large amount unless they
were wearing a brightly colored clown suit. , the price of doing the deal was known . It had both sent in
writing and spoken about on the phone numerous times , a detailed execution plan was provided . then and
only then after all was laid out for the group I was told that after a number of conversations with brad karp
that only 20m would be paid , (and even that was more than originally contemplated ) for both transactions . I
feel It was remarkably unfair. Did brad even know of our prior agreement.? I called him and he said he was
never told.?, I would ask that you I and Brad karp sit together if you think it would be helpful. . I would like to
send him this email, with your consent of course. Ifthe transactions were never consummated , i would not be
owed a dime, however , the price was known up front. , the detailed step by step plan was followed and
overseen by me, the price that had been requested before the transaction was begun, and had Iready heavily
discounted, out of friendship, from our agreement . I believe the decision re paying only 20 m has frankly
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