<table><tr><th>From:</th><th>Jeffrey Epstein &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:</td><td>Tuesday, September 17, 2013 9:14 PM</td></tr><tr><td>To:</td><td>Thomas Turrin</td></tr><tr><td>Subject:</td><td>Re: PRO-FORMA TAX TREATMENT - AIRCRAFT OPERATION</td></tr></table>

can you tell me how many hours this was and how many miles=br>

On =ue, Sep 17, 2013 at 4:40 PM, Thomas Turrin <TTurrin@rem-co.com>=/span> wrote:

Jeffrey,

The attached schedule of pro-forma tax treatment is =ased on actual year 2012 activity and assumes the aircraft was placed in service on Jan 1st= 2012 and was Part 135 for the whole year.

Included in the schedule is the amount of US excise =ax on the gross revenue (including revenue from

business and "personal" use). Under Part 1=5, my understanding is that all of the "revenue"

(including personal use) is subject to 7.5% US excis= tax (per discussion with Pat Fenn at Akin Gump and based on my own research). <=p>

I calculated the loss using bonus depreciation (50%)=and without bonus depreciation.

The operation of the aircraft would be characterized=as a passive activity on Leon's return.

Leon would not be able to claim that he is materiall= participating in an active trade or

business with respect to the aircraft operation (IRC=Code Sec 469). The loss would be deductible to the

extent of Leon's income from other passive activit=es.

Passive activity income does not include portfolio i=come from interest, dividends and

capital gains. Passive activity income is typi=ally real estate rental income as well

as other trade or business income from business acti=ities in which the taxpayer

is not a material participant. <1=>

As a passive activity, the losses not currently dedu=tible against current passive income would not be lost —but would be carried forward as=("suspended") and would offset passive income in future years including income from future disposa= of the aircraft - mostly recapture of depreciation.

Once the aircraft is officially Part 135 (lawyers sa= should be soon), Avioneta Holdings, LLC would become an aircraft business with the aircraft =A0"placed in service" for depreciation purposes.

I'm available to discuss.

Best,

Tom

THOMAS TURRIN, CPA

Email:

Website: www.rem•co.com</=>

=A0

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The information contained in this c=mmunication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized use, di=closure or copying of this communication or any part thereof is strictl= prohibited and may be unlawful. If you have received this communication in error, p=ease notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, =nd destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved

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