<table><tr><th>From:</th><th>jeffrey E. &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:
To:</td><td>Sunday, September 11, 2016 12:52 AM
Pesner, Steven</td></tr><tr><td>Cc:</td><td>Fenn, Patrick; Karp, Brad S</td></tr><tr><td>Subject:</td><td>Re: Reasonable cause statement</td></tr></table>

can josh harris join the call tomorrow? =ight be very helpful.

On Sat, Sep 10, 2016 at 8:30 AM, Pesner, Steven <rnailto: > wrote:

ok<=>>

From: Fenn, Pa=rick
Sent: Saturday, September 10, 2016 8:28 AM
To: Karp, Brad S
Cc: jeeva=ation@gmail.com <mailto:jeevacation@gmail.com> ; Pesner, Steven
Subject: Re: Reasonable cause statement

That works for me. =C2

Patrick B. Fenn=u>

AKIN GUMP STRAUSS H=UER & FELD LLP

Direct: ██████████<tel:██████████>

On Sep 9, 2016, at 11:26 PM, Karp, Brad S <████████████████<mailto:██████████████>> wrote:

How about Sunday at 10 am=

Brad S. Karp I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019.6064

- Document: Email thread screenshot (many personal names/addresses redacted)
- Subject: Re: Reasonable cause statement
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Subject: Re: Reasonable cause statement

<=p>

Did we establish a ti=e to speak tomorrow?

Patrick B. Fenn=u>

AKIN GUMP STRAUSS H=UER & FELD LLP

Direct: <tel:

On Sep 9, 2016, at 7:10 PM, jeffrey E. <jeevacation@gmail.com <mailto:jeevacation@gm=il.com> > wrote:</=>

i think we might consider attaching affidavit=from Apollo - preparer and accounting firm support=ng the actual events. . this is of course as long =s the numbers also tie. . it is true that technically =A0 each filing requires its own reasonable letter. but Pm uncertain whether=one letter that states with specificity, that it applies=to each one by name and year, would qualify. tha= being said one hundred letters and three h=ndred affidavits plus 100 8865s plus 8 1040xs. is quite a package

On Fri, Sep 9, 2016 at 6:35 PM, Fenn, Patrick

<mailto:

<=p>

Will rework over the week=nd for this.

<=>:

From: Jeffrey =. imailto:jeeva=ation@gmailcom <mailto:jeevacation@gmail.com> Sent: Friday, September 09, 2016 6:32 PM To: Fenn, Patrick Subject: Re: Reasonable cause statement

thx, thoughts for discussioin.

i suggest we beef up the backround at a miimum , always =iled on time non deliqent n any filing.. blah blah, =AO resposnilble . biz exec. complex returns alwsays on t=me. no jdugements etc. a character paragraph.. =AO a tax history of no changes? , hired both accounts and lawfirms in the preparation.? . it i= a joint return , do we need to include debra.? i =ould destres the he didnt know. and add that apollo thou=ht and advised otherwise? do we add al= the patners treated the same , no one filed. only in a compliance review=C2 did it get flagged?

On Fri, Sep 9, 2016 at 6:25 PM, Fenn, Patrick

<mailto:██████████>

<=>

As discussed.


Patrick B. Fenn

AKIN GUMP STRAUSS HAUER & FELD LLP

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and

4

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