<table><tr><th>From:</th><th>Heather Gray &lt;</th><th>&gt; </th></tr><tr><td>Sent:</td><td>Thursday, April 30, 2015 6:55 PM</td><td></td></tr><tr><td>To:</td><td>jeffrey E.</td><td></td></tr><tr><td>Subject:</td><td>RE: Re:</td><td></td></tr></table>

I'll check with them.

From: jeffrey E. [mailto:jeevacation@gmail.com]
Sent: Thursday, April 30, 2015 2:48 PM
To: Heather Gray
Subject: Re:

i know them i want to make sure it works for art

On Thu, Apr 30, 2015 at 2:40 PM, Heather Gray <

<mailto » > wrote:

Hi Jeffrey,

I'll find someone at Paul Weiss to discuss this with and will report back. For what it's worth, I think he should absolutely be able to do it under the trade-in credit rules (section 526.5(f) of the Sales and Use Tax Regulations). But I'll find out from the PW folks.

Best,

Heather

From: jeffrey E. [mailto:jeevacation@gmail.com <mailtcyjeevacation@gmail.com> )
Sent: Thursday, April 30, 2015 2:34 PM
To: Heather Gray
Subject:

heather, track down with someone at pw. whether as opposed to a 1031 leon coudl use other fully paid for art to avoid sales tax if traded in to gogosian

this would not shelter gain, only limit sales tax. to picasso minus trade
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