EFTA00716875.txt

"From: Heather Gray To: jeffrey E. ... Subject: RE: question re: possible 1031 Date: Wed, 15 Apr 2015 13:55:31 +0000"

"Heather Gray Elysium Management LLC 445 Park Avenue Suite 1401"

"Narrows Holdings LLC is consigning a Calder mobile to Christie's ... transferred it to Narrows as part of the 2012 contribution"

"Leon bought the Calder from PaceWildenstein in 2009 for $3,758,125 (including NY sales tax)"

"Christie's is giving Narrows a guarantee of $6.5 million, plus 80% of any overage"

"The information contained in this communication is confidential ... It is the property of JEE"

"Leon bought the Calder from PaceWildenstein in 2009 ... and transferred it to Narrows as part of the 2012 contribution of all art to Narrows"

"when was this decided , ?? and yes assignment to a QI ... Should we try to structure this sale as a possible 1031 exchange?"

"transferred it to Narrows as part of the 2012 contribution of all art to Narrows that Ralph prepared."