EMAIL DETAILS

You have a $4000 penalty for late filing of the BG returns. $2000 to you (Sara says they can do half). I don't think it makes sense to appeal - no reason to stir up a hornets nest with this one. Save that for the appeal for your refund. Agree?

Eric D. Schwerin
eschwerin@rosemontseneca.com

Sent from my iPhone

Begin forwarded message:

> From: "Rick Rowland" <rowland@rowlandjohnson.com>
> Date: September 22, 2011 9:20:01 AM EDT
> To: "Eric Schwerin" <eschwerin@rosemontseneca.com>, "Sara Biden" <sbiden@lionhallgp.com>, "Melvyn I. Monzack" <mmonzack@monlaw.com>
> Subject: RE: BG Equity Tax
>

> I'm out of town this week.
>
> The notices are a per partner per month penalty assessed by the IRS for late filing of a partnership return. It seems to me that the alternatives are:
>
> 1. Pay the penalty.
>
> 2. Try to show reasonable cause based on the fact that the Paradigm K-1's weren't available for a timely filing.
>
> The potential issue with trying to get out the penalty is that you have someone else looking into the whole BG Equity/Paradigm structure which might increase IRS audit exposure.
>
> Before deciding how to proceed, I think we need input from all constituencies.
>
>
> Rick
>
> Richard D. Rowland
> (302) 324-0780
> (302) 324-0783 (fax)
> 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: Eric Schwerin [mailto:eschwerin@rosemontseneca.com]
> Sent: Fri 9/16/2011 5:13 PM
> To: Sara Biden; Rick Rowland; Melvyn I. Monzack
> Subject: Fwd: BG Equity Tax
>
>
> FYI, see attached late fee and penalty notice for BG Equity Returns. Sara, we can discuss how to handle these, but also want Mel and Rick in the loop to make sure there is nothing wrong with us paying this.
>
> Thanks,
>
> Eric
>
>
>
>
> Eric D. Schwerin
> Rosemont Seneca Partners, LLC
> 1010 Wisconsin Ave., NW
> Suite 705
> Washington, DC 20007
> (202) 333-1880
> eschwerin@rosemontseneca.com
> P Consider the environment before printing this email.
>
> Begin forwarded message:
>
> From: Joan Peugh <jpeugh@rosemontseneca.com>
>
> Subject: BG Equity Tax
>
> Date: September 16, 2011 3:57:23 PM EDT
>
> To: Eric Schwerin <eschwerin@rosemontseneca.com>
>
>
>
>
> --
> Joan K. Peugh
> Rosemont Seneca Partners
> o: 202-333-1880
> m:202-841-8543
>
>=2