From: Alan S Halperin
Sent: Sunday, September 22, 2013 12:05 PM
To: Jeffrey Epstein; Ada Clapp
Subject: Re:

If your theory were correct, then no transaction betwee==a grantor and his grantor trust would be subject to sales tax. But we know==hat this is not correct. NY has ruled that, if there is consideration, =here is a tax even if the trust is a grantor =rust.

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Alan S. Halperin | =artner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
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From:==/b>"Jeffrey Epstein" [jeevacation@gmail.com]
Sent: =/b>09/22/2013 07:26 AM AST
To: Alan Halperin; "Ada =lapp" <█████████████████████

my argument is that leon is owner for fed income tax =urposed of the promissory note, he owns the =onsideration. and substituties the art. It cannot be =ecognized for sales taz as he owns the same consideration before and =fter. its not that there is no consideration it is==he ownsership of that consideration did not change.

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