<table><tr><th>From:</th><th>Jeffrey &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:</td><td>Thursday, July 5, 2012 5:46 PM</td></tr><tr><td>To:</td><td>Eileen Alexanderson</td></tr><tr><td>Subject:</td><td>Re: follow up</td></tr></table>

Send me grat dots that separate income from capital appreciation

Sorry for all the typos .Sent from my iPhone

On Jul 5, 2012, at 12:09 PM, Eileen Alexanderson wrote:

> Jeffrey, thinking back through dialogs with Carlyn & Elyse and looking at s=me of my old notes from those dialogs that relate to our conversation this m=rning I offer the following:

>

> Regarding the issue of why turning off the income right now works is that i= would be the independent trustees turning off the income right, not Leon, a=d that the 2006 Trust was drafted purposely in anticipation of this. I beli=ve this relates to the language on page 30 in the attached.

>

> Also, Ada (from US Trust) at one point had suggested to Carlyn that we con=ider having the trustees turn of the income right in the 2006 Trust and the= decant the assets from the 2006 Trust into a new trust before proceeding w=th the Art Partnership to insure a cleaner transaction.

>

> Also, on the subject of the 2006 Trust and other trust paying their own ta=es-important implication for Black Family Partners would be that we no long=r have a single taxpayer.

>

> Best,

> Eileen

>

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