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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01192563: Leon Black and Classified (DS9)

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This document is a memorandum dated March 2, 2005, from Amy Heller to files regarding tax consequences of a transaction for Leon Black, with copies to Carlyn McCaffrey and Elyse Kirschner. The memo addresses partnership classification for federal income tax purposes and discusses income from investment assets contributed by a trust, referencing Leon Black's anticipated tax obligations.

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For federal income tax purposes, a "partnership" with only one partner is not a partnership at all; rather, it is **classified** as an entity disregarded from
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Exhibit A March 2, 2005 To: Files cc: Carlyn McCaffrey Elyse Kirschner From: Amy Heller Re: **Leon** **Black** Art Partnership This memorandum summarizes the anticipated
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federal income and New York State sales tax consequences of a transaction being considered for **Leon** **Black** ("Leon").

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