Subject: Re: Paradigm Companies
From: <[email-masked]>
To: "Markus Karr" <[email-masked]>
Date: Wed, 13 Oct 2010 16:05:34 +0000

Why the fuck is this coming up now???   Arrrgghhh

Sent via BlackBerry from T-Mobile

-----Original Message-----
From: "Markus Karr" <[email-masked]>
Date: Wed, 13 Oct 2010 15:48:01 
To: Marc LoPresti<[email-masked]>
Reply-To: [email-masked]
Subject:  Fw: Paradigm Companies

Marc: see point 2 below.  Do you want to run it by Tom?

Markus L. Karr
PARADIGM
[email-masked]

-----Original Message-----
From: Joe Brown <[email-masked]>
Date: Wed, 13 Oct 2010 11:44:10 
To: [email-masked]<[email-masked]>
Subject: Paradigm Companies

Markus,

We have a couple questions on the PComp tax return.

1.       On all partnership tax returns, a tax matters partner is reported.  Generally we use the managing member for LLC tax returns.  So, we have used BG Equity Partners, LLC for the Pcomp return.  However, for 2009 the IRS requires, that when the tax matters partner is an entity, we report an individual and their phone number who can be contacted to discuss the return.  For Pcomp should we list you or someone else as the individual to contact?  If you would like to list someone else, please provide the phone number where they can be contacted.

2.       Since the Note payable to Tom Laurita will not be paid back, we need to remove it from the books of Pcomp.  We have a couple options for removing the note. A) we can report the note as debt forgiveness income to Pcomp which could possibly allow Tom to take an ordinary loss for the note if he has not already written the note off previously; B) we could report the note as a capital contribution.  Option B will limit Tom's options for taking the loss, as it will make it a passive loss in which case he would need other passive income to offset the loss against.  Option B would also be problematic if he has previously taken the loss on the note because it can't be a loss and a capital contribution.  Please let us know which option we should use for reporting the write off of the Tom Laurita Note Payable.

If you have any questions please let me know.

Thanks,

Joe Brown
Tax Senior
201 International Circle, Suite 400
Hunt Valley, MD 21030
Ph: 410-771-0001
Fax: 410-785-9784
[email-masked]<mailto:[email-masked]>

*************************************************************************************
The contents of this message, together with any attachments, are intended only for the use of the individual or entity to which they are addressed and may contain information that is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please notify the original sender.
********************************************************************************************************
IRS Circular 230 Disclosure
To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.