EFTA00863108.txt

"From: Richard Joslin To: jeffrey E. <[email protected]> Date: Wed, 04 Mar 2015 11:28:14 +0000"

"John Suydam agreed that the LP interest in AIF MGT currently held by BFP has no economic value... without creating any tax or regulatory problems for "

"In June 7, 2007, AIF transferred its LP interest in AIF MGT to Black Family Partners, LP (BFP)"

"Elysium Management LLC 445 Park Avenue Suite 1401 New York New York 10022"

"because if the LP interest in AIF MGT did have a value on date of contribution, the cancellation of the BFP interest by an entity that is controlled b"

"Do you have any thoughts on this? ... the cancellation of the BFP interest by an entity that is controlled by Leon may raise gift tax issues"