This memo from Thomas Turrin, CPA, to Jeffrey Epstein discusses the tax implications of contributing encumbered works of art to a partnership between Leon and four 2011 grantor trusts. It covers the potential tax effects of such contributions, the tax status of the partnership during Leon's lifetime, and the changes upon Leon's death, including the step-up in basis for Leon's interest in the partnership.
documents/EFTA01137108.pdf
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