Monday, November 24, 2014

Kelley Lynch's Email To IRS Re. IRS Letter Ruling On Leonard Cohen's Default Judgment, Wrongful Conveyance Of Her Property To Himself, Self-Dealing & Theft Loss To Kelley Lynch

From: Kelley Lynch <>
Date: Mon, Nov 24, 2014 at 3:40 PM
Subject: Letter Ruling
To: "irs.commissioner" <>


I am continuing to attempt to obtain the information Leonard Cohen is required to provide me personally.  I am also attempting to inspect the corporate books, records, and federal tax returns re. numerous entities.  I would like a formal IRS letter ruling before I file my 2004 and 2005 federal tax returns.  I will not be able to do that until I obtain this information and I will note, once again, that contradictory information has been provided to IRS by Leonard Cohen and numerous entities.  

One of my main questions relates to the wrongful conveyance of my property to Cohen's.  I would like to know if I should handle the entire judgment as a theft loss (as accountants have suggested) and what to do with respect to the previously filed federal tax returns related to numerous entities in light of the corporate records, federal tax returns, and the judgment.  I would also like to know how LA Superior Court can take a contrary position to IRS re. ownership interest in these entities and whether or not restraining orders, fraudulent or not, can be used to prevent someone from requesting or receiving tax information.  I would like a formal IRS opinion on the application of illegal interest pre and post judgment and what the IRS believes should happen with respect to Leonard Cohen's approximately $6.7 million in loans from TH entity and the interest (6% per annum) that now totals approximately $4 million bringing the total assets Cohen appears to have embezzled from this entity to $10 million.  Also, given the fact that the assets are owned by BMT, how does the IRS believe this should be handled on a final tax return.  Please keep in mind that Leonard Cohen and his related entities collected the income related to those assets.  No loan documents exist.  Does IRS believe the default judgment is actual evidence of corporate dissolutions?

And, while I have challenged Leonard Cohen's refunds (and the tax returns he submitted and amended for 2003, 2004, and 2005) as fraud, I would like IRS to address those refunds based on the corporate books, records, actual ownership interests, and with respect to previously filed federal tax returns.

Those are my fundamental questions and I have raised self-dealing on Leonard Cohen's part as an issue.

All the best,

A “letter ruling” is a written determination issued to a taxpayer by an Associate office in response to the taxpayer’s written inquiry, filed prior to the filing of returns or reports that are required by the tax laws, about its status for tax purposes or the tax effects of its acts or transactions. A letter ruling interprets the tax laws and applies them to the taxpayer’s specific set of facts. A letter ruling is issued when appropriate in the interest of sound tax administration. One type of letter ruling is an Associate office’s response granting or denying a request for a change in a taxpayer’s method of accounting or accounting period. Once issued, a letter ruling may be revoked or modified for a number of reasons.See section 11 of this revenue procedure. A letter ruling may be issued with a closing agreement, however, and a closing agreement is final unless fraud, malfeasance, or misrepresentation of a material fact can be shown. See section 2.02 of this revenue procedure.