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-----Original Message-----
From: "Markus Karr" <mk@paradigm-ny.com>
Date: Thu, 18 Nov 2010 18:22:51
To: Marc LoPresti<mxl@tlcorplaw.com>
Reply-To: mk@paradigm-ny.com
Subject: Fw: 2009 Tax Return allocations


Markus L. Karr
PARADIGM
mk@paradigm-ny.com


-----Original Message-----
From: Joe Brown <Joe.Brown@arthurbellcpas.com>
Date: Thu, 18 Nov 2010 13:20:43
To: mk@paradigm-ny.com<mk@paradigm-ny.com>
Subject: FW: 2009 Tax Return allocations

Markus,

The status of the BGPC Advisors LLC 2009 tax return has been held up in the same position for the last few weeks with us waiting for Rick Rowland to confirm that they agree with income allocations of the draft return. I have forwarded you his email below that states he recommends accepting the allocations in the draft, however we will need to get confirmation from the Bidens. As I am sure everyone is anxious to finalize the 2009 returns as soon as possible, what do we need to do to get confirmation from the Bidens and move the returns along? If you have any questions please let me know.

Regards,

Joe Brown, CPA
Tax Senior
201 International Circle, Suite 400
Hunt Valley, MD 21030
Ph:410-771-0001
Fax: 410-785-9784
joe.brown@arthurbellcpas.com<mailto:joe.brown@arthurbellcpas.com>
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From: Rick Rowland [mailto:rowland@rowlandjohnson.com]
Sent: Tuesday, November 16, 2010 6:10 PM
To: Joe Brown
Subject: RE: 2009 Tax Return allocations

I recommended that we accept the draft allocations, but you will need confirmation from Hunter and/or Jim before finalizing the returns.


Rick

Richard D. Rowland
(302) 324-0780
(302) 324-0783 (fax)
rrowland@rowlandjohnson.com<mailto:rrowland@rowlandjohnson.com>

Pursuant to requirements of IRS Circular 230, any U.S. tax advice contained in the body of this e-mail was not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax law provisions.

________________________________
From: Joe Brown [mailto:Joe.Brown@arthurbellcpas.com]
Sent: Mon 11/15/2010 5:29 PM
To: Rick Rowland
Subject: RE: 2009 Tax Return allocations
Rick,

I just wanted to check and see if a decision has been reached regarding the allocation reflected in the BGPC draft? If you have any questions please let me know.

Regards,

Joe

From: Rick Rowland [mailto:rowland@rowlandjohnson.com]
Sent: Monday, November 01, 2010 10:57 AM
To: Joe Brown
Subject: RE: 2009 Tax Return allocations

I'm recommending to the Biden holders that we accept the allocations reflected in the draft. I will let you know (or have one of them contact you) when the decision is finalized.

Rick

Richard D. Rowland
Rowland, Johnson & Company, P.A.
2 Read's Way, Suite 100
New Castle, DE 19720
(302)324-0780
Fax (302)324-0783

Pursuant to the requirements of IRS Circular 230, any U.S. tax advice contained in the body of this e-mail is not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state and local tax law provisions.


From: Joe Brown [mailto:Joe.Brown@arthurbellcpas.com]
Sent: Monday, November 01, 2010 10:52 AM
To: Rick Rowland
Subject: RE: 2009 Tax Return allocations

Rick,

I am not sure why there were two of the same emails, but the one I sent Friday afternoon is a revised version of the basis estimate that I sent a week or so ago. I have corrected the estimate basis for BG Equity at Paradigm Companies. Sorry for the confusion. Let us know if you have any questions or if you would like to have a call to discuss further.

Regards,

Joe

From: Rick Rowland [mailto:rowland@rowlandjohnson.com]
Sent: Monday, November 01, 2010 10:36 AM
To: Joe Brown
Subject: RE: 2009 Tax Return allocations

Joe:

I got the same e-mail from you twice. I don't see any differences. Are there any that I should be focusing on?

Rick

Richard D. Rowland
Rowland, Johnson & Company, P.A.
2 Read's Way, Suite 100
New Castle, DE 19720
(302)324-0780
Fax (302)324-0783

Pursuant to the requirements of IRS Circular 230, any U.S. tax advice contained in the body of this e-mail is not intended or written to be used, and cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state and local tax law provisions.


From: Joe Brown [mailto:Joe.Brown@arthurbellcpas.com]
Sent: Friday, October 29, 2010 4:45 PM
To: Rick Rowland
Subject: 2009 Tax Return allocations

Rick,

My apologies for the confusion with the negative basis amount. I was factoring in activity that occurred prior to the 2006 Biden purchase. I have re-ran the numbers only picking up the minimal income/(loss) allocated to the BG entity. I have also removed the Paradigm Companies line from the BGPC level which hopefully makes it easier to look through to the underlying members. After you have had a chance to take a look at the spreadsheet, we can set a phone call next week to discuss, if necessary. Let us know if you have any questions.

Regards,

Joe Brown
Tax Senior
201 International Circle, Suite 400
Hunt Valley, MD 21030
Ph:410-771-0001
Fax: 410-785-9784
joe.brown@arthurbellcpas.com
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