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HomeMy WebLinkAboutExhibit C to Declaration of Tamara Crisp in Support of City of Renton's Opposition to Tracfone's Motion to Compel Audit FileTracFone TRS Renton More Emails 1-17-21 Re: NDAs Sent • TRS <crisp@trs-integrity.com> To:JCAVALIERI@tracfone.com Thu, Nov 7, 2013 at 4:20 PM Hi John, The email date was June 28th. Also, we perform audits for many cities, and we have been contracted by the City of Tukwila to do work for them. They have asked us to do an audit on TracFone for them. We will send you an agent/engagement letter. We will also send the City of Tukwila a copy of the NDA similar to the one that we have used for the other cities. I think you are right, that it would probably be better to wait until we get all of the NDAs signed before you start gathering information. We have been working with the various cities to get the signed NDAs. We will try to get them signed by these cities as soon as possible. Thanks John. Let me know if you have any questions. Mike From: John Cavalieri <JCAVALIERI@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Thursday, November 7, 2013 1:53 PM Subject: RE: NDAs Mike,   Would you kindly tell me the date of the email you requested the info for the Renton audit. I have not started the gathering of any info. Would probably be more efficient to do after all NDA’s are signed.   Thank you, John   John F. Cavalieri | Sr. Manager, Tax | TracFone Wireless, Inc. | O: 305.715.6578 | F: 305.418.2696 | jcavalieri@TracFone.com   From: TRS [mailto:crisp@trs-integrity.com] Sent: Tuesday, November 05, 2013 3:00 PM To: John Cavalieri Subject: NDAs   Hi John, Hope things have been going well with you. I have talked with the City of Burien and they should be sending me a signed copy of the Non-Disclosure Agreement (NDA) soon. I will let you now if they have any questions. Also, we are still waiting for the NDAs for Spokane and Federal Way, as soon as we get them, we will send them to you. Also, have you had a chance to look at the information we need for the Renton audit. Or are you going to wait to get all of the NDAs before you start pulling the information. Let me know if you have any questions. Thanks John. Mike Federal Way NDA Sent • TRS <crisp@trs-integrity.com> To:JCAVALIERI@tracfone.com Thu, Dec 12, 2013 at 3:33 PM Hi John,  Here is the NDA for the City of Federal Way.  After it has been signed, could you send us a copy? Also, how are the other cities coming along with the signatures (Renton, Burien and Spokane)? Let me know if you have any questions. Have a great day. Thanks John. Mike •racFone NDA Federal Way0001.pdf 556kB NDAs Inbox • John Cavalieri <jcavalieri@tracfone.com> To:crisp@trs-integrity.com Cc:CDillon@tracfone.com Tue, Dec 24, 2013 at 8:10 AM Mike,   The same is true for Burien and Spokane. They did not sign the approved NDAs which were initialed by our legal dept on each page. Please have these municipality sign the NDAs provided in the 9/16/13 email. They are attached again here for your convenience. The only municipality that signed the correct NDA is Renton. I will have one prepared and initialed for Tukwila to sign.   Thank you, John   John F. Cavalieri | Sr. Manager, Tax  | TracFone Wireless, Inc. | O: 305.715.6578 | F: 305.418.2696 |  jcavalieri@TracFone.com    From: John Cavalieri Sent: Tuesday, December 24, 2013 10:59 AM To: 'TRS' Cc: Chesley Dillon Subject: RE: Federal Way NDA   Mike,   The NDA you attached or Federal Way is not the one initialed on each page by our legal dept. Please have the attached signed by Federal Way which was provided in the email of 9/16/13   Thank you, John   John F. Cavalieri | Sr. Manager, Tax  | TracFone Wireless, Inc. | O: 305.715.6578 | F: 305.418.2696  | jcavalieri@TracFone.com   From: TRS [mailto:crisp@trs-integrity.com] Sent: Thursday, December 12, 2013 6:33 PM To: John Cavalieri Subject: Federal Way NDA   Hi John,    Here is the NDA for the City of Federal Way.  After it has been signed, could you send us a copy?   Also, how are the other cities coming along with the signatures (Renton, Burien and Spokane)?   Let me know if you have any questions.   Have a great day.   Thanks John.   Mike         <<                 City of Spokane, Tax Recovery, and TF NDA - Sept. 2013.pdf      (737.5KB)                 City of Federal Way, Tax Recovery, TF NDA - Sept. 2013.pdf      (737.4KB)                 City of Renton, Tax Recovery, and TF NDA - Sept. 2013.pdf        (737.2KB)                 City of Burien, TracFone, and Tax Recovery NDA - Sept. 2013.pdf          (738.3KB)                 (2.9MB)         >> City of Spokane, Tax Recovery, and TF NDA - Sept. 2013.pdf 734kB •City of Burien, TracFone, and Tax Recovery NDA - Sept. 2013.pdf 734.8kB •@ Re: NDAs Sent • TRS <crisp@trs-integrity.com> To:JCAVALIERI@tracfone.com Thu, Dec 26, 2013 at 2:13 PM Hi John, We are working on the NDAs and will be getting back with you. Also, let us know if you have any more questions on the waiver forms. Hope you had a great Christmas. Thanks John, Mike From: John Cavalieri <JCAVALIERI@tracfone.com> To: TRS <crisp@trs-integrity.com>  Cc: Chesley Dillon <CDillon@tracfone.com>  Sent: Tuesday, December 24, 2013 8:08 AM Subject: NDAs ----- Forwarded Message ----- Mike,   The same is true for Burien and Spokane. They did not sign the approved NDAs which were initialed by our legal dept on each page. Please have these municipality sign the NDAs provided in the 9/16/13 email. They are attached again here for your convenience. The only municipality that signed the correct NDA is Renton. I will have one prepared and initialed for Tukwila to sign.   Thank you, John   John F. Cavalieri | Sr. Manager, Tax  | TracFone Wireless, Inc. | O: 305.715.6578 | F:  305.418.2696 | jcavalieri@TracFone.com    From: John Cavalieri Sent: Tuesday, December 24, 2013 10:59 AM To: 'TRS' Cc: Chesley Dillon Subject: RE: Federal Way NDA   Mike,   The NDA you attached or Federal Way is not the one initialed on each page by our legal dept. Please have the attached signed by Federal Way which was provided in the email of 9/16/13   Thank you, John   John F. Cavalieri | Sr. Manager, Tax  | TracFone Wireless, Inc. | O: 305.715.6578 | F:  305.418.2696 | jcavalieri@TracFone.com   From: TRS [mailto:crisp@trs-integrity.com] Sent: Thursday, December 12, 2013 6:33 PM To: John Cavalieri Subject: Federal Way NDA   Hi John,    Here is the NDA for the City of Federal Way.  After it has been signed, could you send us a copy?   Also, how are the other cities coming along with the signatures (Renton, Burien and Spokane)?   Let me know if you have any questions.   Have a great day.   Thanks John.   Mike << City of Spokane, Tax Recovery, and TF NDA - Sept. 2013.pdf (737.5KB) City of Federal Way, Tax Recovery, TF NDA - Sept. 2013.pdf (737.4KB) City of Renton, Tax Recovery, and TF NDA - Sept. 2013.pdf (737.2KB) City of Burien, TracFone, and Tax Recovery NDA - Sept. 2013.pdf (738.3KB) (2.9MB) >> Non-Disclosure Agreement (NDA) Sent • TRS <crisp@trs-integrity.com> To:JCAVALIERI@tracfone.com Tue, Feb 18, 2014 at 4:59 PM Hi John, Here is the signed NDA for the City of Burien. Let me know if you have any questions. I believe this is the last one. Also, let me know if you have any questions with the information we requested for the audit. Thanks John. Have a great day. Mike •2SigndTracFoneBurien.pdf RE: Non-Disclosure Agreement (NDA) Inbox • John Cavalieri <jcavalieri@tracfone.com> To:crisp@trs-integrity.com Fri, Feb 21, 2014 at 1:47 PM The NDAs are now all in for signature.    By-the way, I never  received the contract between you and Tukwila.  Please send.   I also never received a letter of intent to audit directly from Tukwila or Renton.  Please send as well.    Thank you, John   John F. Cavalieri | Sr. Manager, Tax  | TracFone Wireless, Inc. | O: 305.715.6578 | F: 305.418.2696 | jcavalieri@TracFone.com    From: TRS [mailto:crisp@trs-integrity.com]  Sent: Tuesday, February 18, 2014 8:00 PM To: John Cavalieri Subject: Non-Disclosure Agreement (NDA)   Hi John,   Here is the signed NDA for the City of Burien.     Let me know if you have any questions.  I believe this is the last one.     Also, let me know if you have any questions with the information we requested for the audit.   Thanks John.   Have a great day.   Mike Re: 6/23/15 Spokane Submittals Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Mon, Jul 6, 2015 at 2:09 PM Thanks, Nicolas. Hope you had a great 4th of July. We are looking forward to receiving the information. Have a great afternoon. Mike This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Monday, July 6, 2015 7:24 AM Subject: RE: 6/23/15 Spokane Submittals Hi Mike – the first part of your question below is still being worked on, as we are just coming out of our month- end closing.   Please see my response to the second part, which I had previously sent to you on 6/25.   I’ll continue forwarding the data for the cities, including Burien.       Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.        From: TRS [mailto:crisp@trs-integrity.com]  Sent: Tuesday, June 30, 2015 8:32 PM To: Nicholas Ford Subject: 6/23/15 Spokane Submittals   Hi Nicholas, Hope all is well with you. Also, wanted to check and see if you had a chance to look at the email that we sent to you (see below). Let us know if you have any questions. Thanks Nicholas. Have a great evening. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Wednesday, June 24, 2015 4:38 PM Subject: 6/23/15 Spokane Submittals   Hi Nicholas, Hope all is well with you. Thank you for the Spokane information you have been sending. We have been going through the information, and we have some initial questions: -On the Billing Platform sheets. First, in the Tax 911 column, is this the State-only tax, or the State plus county tax for this zip? Second, what is the Amount column for? Third, how is this amount related to the 911 tax? We see there is a regular mathematical relationship, but since 911 is calculated on a per line monthly charge, where do the values in the Amount column come from?   -In an email dated October 21, 2014, you mentioned that you were in the process of pulling State-wide data for the audit, but we never received this. It looks like we will need to see your combined Excise State of Washington tax returns, one from each year of the audit; for each, please send the month of June.   My October 21, 2014 e-mail indicated that I was pulling State-wide data in connection with a WA State excise tax audit, in which case there would be overlap in the data where the local cities such as Spokane, WA is concerned.  That said, it is our position that Spokane’s taxing authority is limited to Spokane’s city limits, and that there is no power to request WA State-wide data.   We would take the same position regarding the other WA cities under audit as well.   Please reply to the questions and requests above as soon as possible, as Spokane is anxious to see progress on this audit.   Also, we are still reviewing the items that were requested on the audit and will get back with you.   Thank Nicholas.   Mike Re: TracFone-Federal Way, WA Utility Users' Tax Audit -- Jan. 1 2008 to Dec. 31 2008 -- Utility Users' Tax Returns Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Mon, Jul 28, 2014 at 1:24 PM Hi Nicholas, Thanks for the tax returns. Let us know if you have any questions with any of the information that was requested for the audit. Have a great afternoon. Mike From: Nicholas Ford <nford@tracfone.com> To: "crisp@trs-integrity.com" <crisp@trs-integrity.com>  Sent: Monday, July 28, 2014 8:44 AM Subject: TracFone-Federal Way, WA Utility Users' Tax Audit -- Jan. 1 2008 to Dec. 31 2008 --  Utility Users' Tax Returns Hi Mike -- In regard to your TracFone-Federal Way, Washington State Utility Users' Tax Audit, please find attached to this e-mail a zip file containing TracFone’s Telephone Utility Users’ Tax Returns for the January 1, 2008 to December 31, 2008 period.      * Federal Way, Washington State Utility Users' Tax Returns for the remaining periods under audit will be sent under separate e-mails.*   Regards,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com   Tax Returns and information for the audit Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Sep 4, 2014 at 2:38 PM Hi Nicholas, Hope things have been going good for you. Thanks for all of the utility tax returns.  It looks like we just have the City of Tukwila and Burien left for the returns.  Also, I wanted to check and see how things are coming along with the other information that we requested for the audit and the information mentioned below.  The cities have asked me to prepare updates for them to let them know how things are coming along. Let me know if you have any questions.   Have a great day. Mike From: TRS <crisp@trs-integrity.com> To: "nford@tracfone.com" <nford@tracfone.com>  Sent: Friday, June 20, 2014 2:58 PM Subject: TracFone: Key issues regarding municipal taxation of calling cards Hi Nicholas, It was good talking with you. We also wanted to ask you a few questions concerning the telephone prepaid cards:    How does TracFone keep track of sales and revenue? Does TracFone source calls at all? How does TracFone keep record of calls and minutes used? Does TracFone break calls and revenues down geographically, i.e. jurisdictionally? Does TracFone keep track of the primary residence of the customers (primary place of use)?   This would include both pre-paid calling cards and recharges. Also, it is our understanding that TracFone has several brands (telephone cards) that they sell.  These include: TracFone, Net10, StraightTalk, Simple Mobile, Telcel America. If there are any other brands, please include those also with the information that we have requested for the audit. Lastly, we have checked with the cities of Renton, Tukwila and Burien and they would like to go ahead and extend the audit out to May 31, 2014. At this point, it would also probably be good to extend Federal Way out to May 31, 2014, too The City of Spokane would like to exten the audit out to March 31, 2014.  By doing it this way, your company will not have to go back and prepare all of these month's tax returns yourself to catch up, and we can bring everything current as much as possible.     At this point, we will not need any additional information due to the extensions. Let me know if you have any questions concerning the items above or any questions on the information that was requested for the audit. Thanks Nicholas.  We look forward to working with you on these audits. Have a great weekend. Mike     This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  6/23/15 Spokane Submittals Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Jun 24, 2015 at 4:38 PM Hi Nicholas, Hope all is well with you. Thank you for the Spokane information you have been sending. We have been going through the information, and we have some initial questions: -On the Billing Platform sheets. First, in the Tax 911 column, is this the State-only tax, or the State plus county tax for this zip? Second, what is the Amount column for? Third, how is this amount related to the 911 tax? We see there is a regular mathematical relationship, but since 911 is calculated on a per line monthly charge, where do the values in the Amount column come from? -In an email dated October 21, 2014, you mentioned that you were in the process of pulling State-wide data for the audit, but we never received this. It looks like we will need to see your combined Excise State of Washington tax returns, one from each year of the audit; for each, please send the month of June. Please reply to the questions and requests above as soon as possible, as Spokane is anxious to see progress on this audit. Also, we are still reviewing the items that were requested on the audit and will get back with you. Thank Nicholas. Mike Thanks, Nicolas. Mike This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  RE: 6/23/15 Spokane Submittals Inbox • Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Thu, Jun 25, 2015 at 10:36 AM Hi Mike – I am looking at the 1st segment of your questions below, with the aim of providing feedback next week.  Please note that our V.P. of Tax is out of the office until Monday, June 29th.      Regarding the 2nd segment of your question, my October 21, 2014 e-mail indicated that I was pulling State-wide data in connection with a WA State excise tax audit, in which case there would be overlap in the data where the local cities such as Spokane, WA is concerned.  That said, it is our position that Spokane’s taxing authority is limited to Spokane’s city limits, and that there is no power to request WA State-wide data.   We would take the same position regarding the other WA cities under audit as well.   Regards,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.            From: TRS [mailto:crisp@trs-integrity.com]  Sent: Wednesday, June 24, 2015 7:38 PM To: Nicholas Ford Subject: 6/23/15 Spokane Submittals   Hi Nicholas, Hope all is well with you. Thank you for the Spokane information you have been sending. We have been going through the information, and we have some initial questions: -On the Billing Platform sheets. First, in the Tax 911 column, is this the State- only tax, or the State plus county tax for this zip? Second, what is the Amount column for? Third, how is this amount related to the 911 tax? We see there is a regular mathematical relationship, but since 911 is calculated on a per line monthly charge, where do the values in the Amount column come from?   -In an email dated October 21, 2014, you mentioned that you were in the process of pulling State-wide data for the audit, but we never received this. It looks like we will need to see your combined Excise State of Washington tax returns, one from each year of the audit; for each, please send the month of June.   Please reply to the questions and requests above as soon as possible , as Spokane is anxious to see progress on this audit.   Also, we are still reviewing the items that were requested on the audit and will get back with you.   Thank Nicholas.   Mike Thanks, Nicolas.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it. NOTE: The response to the July 6, 2015 email from TracFone cannot be found on my server, but it is preserved in the email chain below our reply on July 6.. Re: 6/23/15 Spokane Submittals Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Mon, Jul 6, 2015 at 2:09 PM Thanks, Nicolas. Hope you had a great 4th of July. We are looking forward to receiving the information. Have a great afternoon. Mike This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Monday, July 6, 2015 7:24 AM Subject: RE: 6/23/15 Spokane Submittals Hi Mike – the first part of your question below is still being worked on, as we are just coming out of our month- end closing.   Please see my response to the second part, which I had previously sent to you on 6/25.   I’ll continue forwarding the data for the cities, including Burien.       Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.  From: TRS [mailto:crisp@trs-integrity.com]  Sent: Tuesday, June 30, 2015 8:32 PM To: Nicholas Ford Subject: 6/23/15 Spokane Submittals   Hi Nicholas, Hope all is well with you. Also, wanted to check and see if you had a chance to look at the email that we sent to you (see below). Let us know if you have any questions. Thanks Nicholas. Have a great evening. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Wednesday, June 24, 2015 4:38 PM Subject: 6/23/15 Spokane Submittals   Hi Nicholas, Hope all is well with you. Thank you for the Spokane information you have been sending. We have been going through the information, and we have some initial questions: -On the Billing Platform sheets. First, in the Tax 911 column, is this the State-only tax, or the State plus county tax for this zip? Second, what is the Amount column for? Third, how is this amount related to the 911 tax? We see there is a regular mathematical relationship, but since 911 is calculated on a per line monthly charge, where do the values in the Amount column come from?   -In an email dated October 21, 2014, you mentioned that you were in the process of pulling State-wide data for the audit, but we never received this. It looks like we will need to see your combined Excise State of Washington tax returns, one from each year of the audit; for each, please send the month of June.   My October 21, 2014 e-mail indicated that I was pulling State-wide data in connection with a WA State excise tax audit, in which case there would be overlap in the data where the local cities such as Spokane, WA is concerned.  That said, it is our position that Spokane’s taxing authority is limited to Spokane’s city limits, and that there is no power to request WA State-wide data.   We would take the same position regarding the other WA cities under audit as well.   Please reply to the questions and requests above as soon as possible, as Spokane is anxious to see progress on this audit.   Also, we are still reviewing the items that were requested on the audit and will get back with you.   Thank Nicholas.   Mike   Re: TracFone-Renton, WA Utility Users' Tax Audit -- Retail (Direct) Sales Summary Reports -- FOR DECEMBER 2009 Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Jul 29, 2015 at 5:21 PM Hi Nicholas, Hope things are going well with you. Did you get a chance to review the information that we requested in a previous email: -On the Billing Platform sheets. First, in the Tax 911 column, is this the State-only tax, or the State plus county tax for this zip? Second, what is the Amount column for? Third, how is this amount related to the 911 tax? We see there is a regular mathematical relationship, but since 911 is calculated on a per line monthly charge, where do the values in the Amount column come from? -In an email dated October 21, 2014, you mentioned that you were in the process of pulling State-wide data for the audit, but we never received this. It looks like we will need to see your combined Excise State of Washington tax returns, one from each year of the audit; for each, please send the month of June. Also, I wanted to check and see how Federal Way's information is coming along. We will be out of the office until early next week.  In case of an emergency, you can contact n.crisp@trs-integrity.com. Thanks Nicholas. Have a great weekend. Mike This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Wednesday, July 29, 2015 8:48 AM Subject: TracFone-Renton, WA Utility Users' Tax Audit -- Retail (Direct) Sales Summary Reports -- FOR  DECEMBER 2009 Hi Mike – in connection with the TracFone-Renton, WA Utility Users' Tax Audit, please find attached the Company’s retail (direct) sales summary reports for the  December 2009   audit month.   It should be noted that TracFone does notearn revenue in the City of Renton, Washington.   **Additional data relating to the remaining audit periods for Burien are forthcoming in separate e-mails.**   Thanks,     Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.    TracFone-Renton Utility Users' Tax Audit -- Responses to Questions Inbox • Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Thu, Aug 13, 2015 at 8:07 AM Hi Mike – below are responses to several of the questions regarding Renton, WA that we had received in respect to the ongoing Utility Users' Tax Audit. Ø  A list of all revenue figures by account category earned in Washington State for each year of the audit. ·         It is our position that Renton’s taxing authority is limited to the city limits of Renton, and that there is no power to request Washington State-wide data. Ø  Information on how TracFone Wireless sources calls. ·         TracFone does not source calls. Ø  Information on how TracFone Wireless keeps record of calls and minutes used. ·         TracFone does not own or operate any telephone facilities. Rather, it resells airtime purchased from third party carriers. The company receives some limited information about calls from the carriers. Ø  Information on how TracFone Wireless breaks calls and revenues down geographically, i.e. jurisdictionally. If they only break them down state-wise, show how this is done. ·         TracFone does not break calls down geographically, and the information received from carriers provides a limited ability to do so. We have some ability to identify redemption of airtime geographically and do so using the zip code assigned to the handset upon activation. Ø  Information on whether TracFone Wireless keeps track of the primary residence of the customers (primary place of use). ·         TracFone does not utilize primary place of use (PPU).   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |   nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above. Re: TracFone-Renton Utility Users' Tax Audit -- Responses to Questions Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Aug 13, 2015 at 2:00 PM Hi Nicholas, Thanks for the email.  We will review your answers and get back with you.    Also, do you know how soon it will be when you will be able to get back with us concerning the email that was sent on July 29th (see below)?  -On the Billing Platform sheets. First, in the Tax 911 column, is this the State-only tax, or the State plus county tax for this zip? Second, what is the Amount column for? Third, how is this amount related to the 911 tax? We see there is a regular mathematical relationship, but since 911 is calculated on a per line monthly charge, where do the values in the Amount column come from? Let us know if you have any questions. Have  a good afternoon. Mike From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Thursday, August 13, 2015 7:57 AM Subject: TracFone-Renton Utility Users' Tax Audit -- Responses to Questions Hi Mike – below are responses to several of the questions regarding Renton, WA that we had received in respect to the ongoing Utility Users' Tax Audit. Ø  A list of all revenue figures by account category earned in Washington State for each year of the audit. ·         It is our position that Renton’s taxing authority is limited to the city limits of Renton, and that there is no power to request Washington State-wide data. Ø  Information on how TracFone Wireless sources calls. ·         TracFone does not source calls. Ø  Information on how TracFone Wireless keeps record of calls and minutes used. ·         TracFone does not own or operate any telephone facilities.  Rather, it resells airtime purchased from third party carriers.  The company receives some limited information about calls from the carriers. Ø  Information on how TracFone Wireless breaks calls and revenues down geographically, i.e. jurisdictionally. If they only break them down state-wise, show how this is done. ·         TracFone does not break calls down geographically, and the information received from carriers provides a limited ability to do so. We have some ability to identify redemption of airtime geographically and do so using the zip code assigned to the handset upon activation. Ø  Information on whether TracFone Wireless keeps track of the primary residence of the customers (primary place of use). ·         TracFone does not utilize primary place of use (PPU).   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.  Fw: TracFone-Kennewick Utility Users' Tax Audit -- Responses to Questions Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Oct 14, 2015 at 3:58 PM Hi Nicholas, Hope things are good for you. Also checking in to see how things are coming along with the questions that we sent to you on August 27th. Let us know if you have any questions. Thanks Nicholas. Mike ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Monday, October 5, 2015 2:59 PM Subject: TracFone-Kennewick Utility Users' Tax Audit -- Responses to Questions Hi Nicholas, Hope things have been going well with you. I also wanted to check and see if you have had a chance to answer our question below that we sent on August 27th. Let us know if you have any questions. Thanks Nicholas. Have a great afternoon. Mike ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Tuesday, September 15, 2015 2:39 PM Subject: Fw: TracFone-Kennewick Utility Users' Tax Audit -- Responses to Questions Hi Nicholas, Hope all is well with you. I also waned to check and see if you have had a chance to answer the question that we sent to you below. Let us know if you have any questions. Thanks Nicholas. Have a great afternoon. Mike ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Thursday, August 27, 2015 12:47 PM Subject: Re: TracFone-Kennewick Utility Users' Tax Audit -- Responses to Questions Hi Nicholas, Below you say "We have some ability to identify redemption of airtime geographically and do so using the zip code assigned to the handset upon activation ." Would you please explain what ability you have to identify airtime redemption geographically by zip?  Thanks, Mike From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Thursday, August 13, 2015 8:04 AM Subject: TracFone-Kennewick Utility Users' Tax Audit -- Responses to Questions Hi Mike – below are responses to several of the questions regarding Kennewick, WA that we had received in respect to the ongoing Utility Users' Tax Audit. Ø  A list of all revenue figures by account category earned in Washington State for each year of the audit. ·         It is our position that Kennewick’s taxing authority is limited to the city limits of Kennewick, and that there is no power to request Washington State-wide data. Ø  Information on how TracFone Wireless sources calls. ·         TracFone does not source calls. Ø  Information on how TracFone Wireless keeps record of calls and minutes used. ·         TracFone does not own or operate any telephone facilities.  Rather, it resells airtime purchased from third party carriers.  The company receives some limited information about calls from the carriers. Ø  Information on how TracFone Wireless breaks calls and revenues down geographically, i.e. jurisdictionally. If they only break them down state-wise, show how this is done. ·         TracFone does not break calls down geographically, and the information received from carriers provides a limited ability to do so. We have some ability to identify redemption of airtime geographically and do so using the zip code assigned to the handset upon activation. Ø  Information on whether TracFone Wireless keeps track of the primary residence of the customers (primary place of use). ·         TracFone does not utilize primary place of use (PPU).   Thanks,     Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com   TracFone-City of Burien, Washington Telephone Utility Tax Audit -- Attachments: March 2012 Sample Period Reconciliation -- Customer Transaction-Level Inbox • Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Thu, Feb 25, 2016 at 3:16 PM Hi Mike -- in connection with the City of Burien, Washington Telephone Utility Tax Audit, please find attached the customer transaction-level detail files for the March 2012 Sample Period for reconciliation purposes.   The brands associated with the transactions are also shown in each of the attached files.   Note:  the customer transaction-level detail files for the remaining sample months related to the other WA cities under audit are forthcoming in separate e-mails.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |   nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.   Download all attachments as a zip file •20160225 - TracFone-Burien WA Audit March 2012 APPT Transaction Detail.xlsx 44kB •20160225 - TracFone-Burien WA Audit March 2012 BP Transaction Detail.xlsx 30.7kB •20160225 - TracFone-Burien WA Audit March 2012 PhonesTransaction Detail.xlsx 14.6kB Re: TracFone-City of Federal Way, Washington Telephone Utility Tax Audit -- Attachments: November 2014 Sample Period Reconciliation -- Customer Transa Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Mar 10, 2016 at 12:50 PM Thanks Nicholas for all of the emails.  We are reviewing them and will get back with you. We also wanted to check and see how things are coming along with our second question (on the email that we sent to you on December 11th) concerning whether or not all of the retail store revenues are included in the revenues that you sent to us, and if they are, can you send us information for each month that we are currently reviewing to verifying that this is occurring?   Let us know if you have any questions. Thanks Tony. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Monday, March 7, 2016 11:33 AM Subject: TracFone-City of Federal Way, Washington Telephone Utility Tax Audit -- Attachments: November 2014 Sample Period Reconciliation -- Customer Transaction-Level Detail Files   Hi Mike -- in connection with the City of Federal Way, Washington Telephone Utility Tax Audit, please find attached the customer transaction-level detail files for the  November 2014 Sample Period for reconciliation purposes.   The brands associated with the transactions are also shown in each of the attached files.   Note:  the customer transaction-level detail files for the remaining sample months related to the other WA cities under audit are forthcoming in separate e-mails.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.    •Fw: TracFone-City of Federal Way, Washington Telephone Utility Tax Audit -- Attachments: November 2014 Sample Period Reconciliation -- Customer Transa Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Mar 18, 2016 at 1:30 PM Hi Nicholas, We are just about done reviewing the emails that you sent to us and will be responding to you soon. Also, I wanted to check and see how things are coming along with the second part of our email below.  Let us know if you have any questions. Thanks Nicholas. Have a great afternoon. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Thursday, March 10, 2016 12:50 PM Subject: Re: TracFone-City of Federal Way, Washington Telephone Utility Tax Audit -- Attachments: November  2014 Sample Period Reconciliation -- Customer Transaction-Level Detail Files Thanks Nicholas for all of the emails.  We are reviewing them and will get back with you. We also wanted to check and see how things are coming along with our second question (on the email that we sent to you on December 11th) concerning whether or not all of the retail store revenues are included in the revenues that you sent to us, and if they are, can you send us information for each month that we are currently reviewing to verifying that this is occurring?   Let us know if you have any questions. Thanks Tony. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Monday, March 7, 2016 11:33 AM Subject: TracFone-City of Federal Way, Washington Telephone Utility Tax Audit -- Attachments: November 2014 Sample Period Reconciliation -- Customer Transaction-Level Detail Files   Hi Mike -- in connection with the City of Federal Way, Washington Telephone Utility Tax Audit, please find attached the customer transaction-level detail files for the  November 2014 Sample Period for reconciliation purposes.   The brands associated with the transactions are also shown in each of the attached files.   Note:  the customer transaction-level detail files for the remaining sample months related to the other WA cities under audit are forthcoming in separate e-mails.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.    Re: TracFone Audit Questions - Responses Sent • TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Aug 26, 2016 at 1:42 PM Hi Nicholas, Thanks for the email regarding definitions.  After reviewing your definitions of the items below, we were wondering if the following are included in the revenue figures you sent to us? All sales of the category 6102 "Pay as you Go" prepaid wireless services (airtime), voice and texting related to customers in the Spokane area.  The sales of the category 6113 of Monthly Programs for prepaid wireless services (airtime), voice and texting related to customers in the Spokane area.  The sales of the category 6202 of BYOP related to customers in the Spokane area. And , if not, are part of these revenues included in the revenue figures that you sent to us?   We also need to see category 6308 revenues received for advertising (also include a copy of the contracts between ad sellers and TracFone) for advertising related to customers in the Spokane area. Thanks Nicholas. Let us know if you have any questions. Have a great day. Mike This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Wednesday, August 17, 2016 11:12 AM Subject: RE: TracFone Audit Questions - Responses   Hi Mike – please see below responses regarding your chart of accounts related questions.  Please be aware that I should have feedback related to your questions on the retail sales, wholesale sales and airtime revenue (where I had sent you some roughly estimated percentage amounts) next week sometime.     Account Number(s)                                                   Description   6102                                                    Airtime Revenue Ø  Sales of prepaid wireless service (airtime) of  voice, data (internet), and texting  under the “Pay as you go” or “PayGo” Airtime coverage, whereby  minutes and days of service can be added as according to a customer’s needs.  Includes retail and wholesale sales (to retailers).   6112                                                    Revenue - TF Service Protection Ø  Sales of TF service protection plans, whereby customers can enroll and protect their service by receiving a 30-day service only extension if needed and add any airtime cards or minutes.   6113                                                    Revenue - Monthly Program Ø  Sales of prepaid wireless service (airtime) of voice, data (internet), and texting under the monthly plans program.  For example, monthly plans of varying periods—of up to one year—are offered.   6118                                                    Revenue - Safelink Program Ø  The Lifeline service (“Safelink”) is a program that enables low-income households to afford phone service.  In the Safelink (Lifeline) Program, TracFone gives airtime (minutes) service free-of- charge to eligible, low-income participants.  In turn, TracFone receives payments, which are reimbursements by USAC for TracFone’s participation in the Safelink program.   6202                                                    BYOP Revenue Ø  Sales of TracFone BYOP packages, which include the BYOP SIM card.  BYOP stands for Bring Your Own Phone. With TracFone's Bring Your Own Phone program, a customer can get TracFone service on their current phone.       6303                                                    Revenue – Other Ø  Miscellaneous Revenue not related to operating activity.   6305                                                    Revenue - ILD Cards Ø  Sales of international long distance (“ILD”) prepaid wireless service (airtime) of voice, data (internet), and texting.   ILD makes it easy for wireless customers to make international calls.   6306                                                    Mobile Advertising Revenue Share Ø  Tracfone owns an inventory of “spaces” that its sells to ad networks (ad resellers). TracFone’s subscribers will see ads from several companies in apps, and then the ad networks will pay Tracfone for the use of these “spaces”.     6308                                                    Revenue - Advertising Ø  See 6306 above.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.        From: TRS [mailto:crisp@trs-integrity.com]  Sent: Monday, August 15, 2016 3:46 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nichols,   Hope things are going well with you and that things are starting to slow down.   Also, wanted to check and see how things are coming along with the information that we requested for the audit.   Let us know if you have any questions.   Thanks Nicholas.   Have a great afternoon.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Friday, August 5, 2016 7:35 AM Subject: RE: TracFone Audit Questions - Responses   Hi Mike – we’re just wrapping up our month end closing.  I had prepared a draft of responses to your questions and will circle back to my contact today, who was reviewing.   Thanks for your patience,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.        From: TRS [mailto:crisp@trs-integrity.com]  Sent: Thursday, August 04, 2016 6:02 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Just checking to see how things are coming along with the information that we requested on June 30th and April 29th.   Let us know if you have any questions.   Thanks Nicholas.   Have a great afternoon.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Thursday, July 28, 2016 5:00 PM Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Hope all is well with you.   I also wanted to check and see how things are coming along with the information that we requested for the audit.   Let us know if you have any questions.   Thanks Nicholas.   Have a great day.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Tuesday, July 19, 2016 2:40 PM Subject: RE: TracFone Audit Questions - Responses   Hi Mike – just a heads up that I’ve been working on your questions, however the Head of Tax and myself will be out of the office the rest of this week until Monday.  As such, I’d aim to get feedback to you sometime next week.   Thanks,     Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.        From: TRS [mailto:crisp@trs-integrity.com]  Sent: Tuesday, July 12, 2016 5:08 PM To: Nicholas Ford Subject: Fw: TracFone Audit Questions - Responses   Hi Nicholas,   Looking at our June 30 email below, we noticed that we made a typo of sorts. In item (3), we put the word "without," when we actually meant "with." Hopefully, from context, you caught our intended meaning and have been framing your reply accordingly, but just in case, we wanted to clarify.    Let us know if you have any questions.   Have a great day.   Thanks Nicholas.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Friday, July 8, 2016 2:01 PM Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Hope everything is going great for you.   Also, wanted to check and see how things are coming along with the email below and if you have any questions.   Thanks Nicholas.   Have a great weekend.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Thursday, June 30, 2016 4:08 PM Subject: Re: TracFone Audit Questions - Responses   Hi Nicolas,   Thanks for the information you sent. It is very helpful for us to understand the terminology used inside your company.   Regarding the calculations you sent us to back up the 30%, this is a good start, but we do have a few further questions.    1) If all of the Direct Sales Amount is "retail," and all of the Airtime Revenue is "wholesale," then, to find what percentage of total sales are Direct Sales, it looks like to me that we should add Direct and Airtime and divide Direct by the sum. Using this method, we arrive at 23.6% and 25.9%.   2) You are dividing two numbers, one is the Direct Sales Amount, and the other is the Airtime Revenue. We were wondering: are you dividing two things that are similar enough to compare? It seems that Direct Sales would include more than just airtime revenue, probably including handset sales and internet? So could you give a definition of each one, including what components they contain?   3) We were looking at the monthly reports you sent a while back, and the amounts from earlier years were so very much smaller than the amounts for more current years, yet company profits appeared high. Has the percentage of sales (comparing ones made without using another retailer to ones being done directly by TracFone) changed significantly over the years? At this point, it looks like we will need to see the figures used for calculating the percentages for each year, rather than just for a few recent years.  Could you send us this information?   Also, let us know if you have any questions concerning the April 29th email that we sent to you.   Thanks Nichols for all of your help.   Have a great 4th of July weekend.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Tuesday, June 28, 2016 12:25 PM Subject: RE: TracFone Audit Questions - Responses     Hi Mike – please see my responses below to your questions (per your 6/24 e-mail):   (1)   What is Internet (APP)?   Ø  The Alternative Payment Plan (“APP”) is TracFone’s credit card transaction interface for retail sales.  Under the APP, customers engage in one-time credit card based transactions via the internet or phone.   APP based customer transactions are consummated predominantly via the internet.  Furthermore, any TracFone plan program which is not available to be set up for an automated-recurring charge gets processed through APP.    (2)    What is Billing Platform?   Ø  The Billing Platform (“BP”) is a supplement to the Alternative Payment Plan (“APP”) to provide a system for automated-recurring charges.  Customers can make a one-time purchase or enroll into programs available for automated or recurring charges, most of which include airtime on a monthly (30 day) basis.    Based on the above, both APP and Billing Platform are internet-based credit card transaction interfaces for executing TracFone’s customers’ retail purchases—except that Billing Platform provides for recurring charges whereas APP allows customers to engaged in one-time credit card transactions.   (3)      Retail Sales Comprise Roughly 30% of TracFone’s sales.     Below shows the breakdown for 2013 and 2014, for example.     2013 Direct Sales Amounts (Per Accum. Summary Reports for '13) Company-Wide         1,658,066,825   31%Retail Sales Percentage Airtime Revenue (Per Financial Statements)Company-Wide      5,358,559,000  69% Wholesale Sales Percentage 2014 Direct Sales Amounts (Per Accum. Summary Reports for '14)Company-Wide         2,144,494,356   35%Retail Sales Percentage Airtime Revenue (Per Financial Statements)Company-Wide      6,126,893,000  65% Wholesale Sales Percentage   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.      From: TRS [mailto:crisp@trs-integrity.com]  Sent: Friday, June 24, 2016 4:35 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses Hi Nicholas,   Thanks for your responses.  After reviewing your reports again we want to make sure we understand what each report is showing, so could you review with us the definition for each report below:   Platform report   APPT report   In other words, is the Billing Platform Report sales for website or phone sales or both?   And the APPT report sales would be for? The sheets say "internet," but we want to ascertain if this means that they were sales made over the internet, not sales of internet (data plans). Perhaps all of your sales are made in bundles, without breaking out data from telephone services?   In addition, do you have any back-up information for the 30 percent figure for your retail sales verses non-retail sales? We were wondering, as well, if this percent changed significantly over time?   Let us know, also, if you have any questions on the April 29 email.   Thanks Nicholas.   Have a great weekend.   Mike     This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Friday, June 24, 2016 8:06 AM Subject: RE: TracFone Audit Questions - Responses     Hi Mike – please see my responses to your questions below in bold blue font.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.          From: TRS [mailto:crisp@trs-integrity.com]  Sent: Tuesday, June 21, 2016 5:01 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Thanks for the email, and all the clarification you provided. We do appreciate it.   I was reviewing your answers to our questions below, and I noticed that you omitted one of the questions, the one asking for a percentage of revenues that come from other stores:   ". . . could you tell us the percentage of your revenues that come from your stores versus the revenues that come from other stores?"  As indicated my original response, TracFone is a reseller of prepaid wireless service (airtime) thatneither owns any stores nor cellular facilities.  Your answers below seem to indicate that both sales from other stores (which sales TracFone does not consider "retail"), and any recharges (or what TracFone calls "refills") associated with those sales, were not included in the figures you sent us. Please verify if this is the correct understanding.  Not correct:  TracFone does not own any stores.  Refills are retail sales of airtime.  As such, customers can purchase additional airtime (refills) via the internet (i.e., TracFone’s website), and over the phone.  Refills are included in the Billing Platform and Internet Sales retail sales summary reports/figures that I had sent to you.    So could you send us the percentage breakout between your sales at your Website and by phone (which we believe you call retail) and your other sales (non-"retail," including refills or what we call recharges on the non-retail sales)?   Retail sales comprise roughly 30% of TracFone’s sales. Also, let me know if you have any questions concerning the email that we sent to you on April 29th, concerning other revenues that TracFone receives. Working on… Have a great afternoon.   Mike This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Friday, June 17, 2016 8:34 AM Subject: RE: TracFone Audit Questions - Responses     Hi Mike – please see responses below to your questions.  *Please note that I am still reviewing your questions related to TracFone’s chart of accounts.*   Billing Platform Transaction Detail Report:  What is?:  ·         OTAPURCH -- ‘over the air’ purchase of prepaid wireless services (airtime) by a customer through the phone. ·         Enrollment --  initial (one-time) enrollment of a customer when purchasing airtime.  ·         Recurring -- using the Billing Platform, customers make a one-time purchase or enroll into programs available for recurring charges, most of which include airtime on a monthly (30 day) basis.   ·         BN Enrollment – ‘Buy Now-Airtime on Demand’ enrollment’, which allows customers to choose and buy Airtime directly from their TracFone, so that they can buy Airtime when they need it.   Also, does TracFone receive their revenues for features such as call waiting sold to their customers, or are they part of the plan when you sell your cards?   No, TracFone does not receive revenues for call waiting.  The feature is part of the airtime plan that customers purchase, thus it is not a separate charge.   After thinking about it, we had some other questions.  You mentioned below that the data that you provided to us does not include retailers such as Walmart.  So the revenue figures that you sent to us are for your own stores?  First off, TracFone is a reseller of prepaid wireless service (airtime) that neither owns any stores nor cellular facilities.  It should also be noted that TracFone does not earn revenue in Burien, Federal Way, Kennewick, Renton, Spokane, or Tukwila.   As such, the Billing Platform, Internet Sales, and Telephone Sales excel format reports that you received comprise TracFone’s retail sales amounts.  These amounts, which are all of the Company’s retail sales, are from customer purchases made via the internet (i.e., the TracFone’s website) and over the phone.     Recharges on Sales Made by Outside Stores Such as Walmart:   One more question we forgot to ask you: when you send us the revenue information that we asked about in the email below, could you also include the charges to customers who have continued to use your services (directly through your drawing funds from their credit card or bank account) after they bought a phone or calling card from one of your outside retailers (like Walmart)? We generally refer to these charges as "recharges." Or are these charges included in the figures you already sent?  Refills of airtime that a customer can purchase at retail via the internet (i.e., the TracFone’s website), and over the phone.  They are included in the Billing Platform and Internet Sales retail reports that you received.   Recharges on Sales Made by TracFone's Own Stores:   In addition, we will need to ascertain that all recharges done on accounts opened at your own stores are included somewhere in the information we are provided with, as well: are charges (associated with sales that initiated at one of your stores) for continued services which were completed by automatic withdrawals or telephone withdrawals included in the figures you sent to us? If not, we will need access to these numbers as well.   See response to question above.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.    From: TRS [mailto:crisp@trs-integrity.com]  Sent: Friday, June 10, 2016 3:29 PM To: Nicholas Ford Subject: TracFone Audit   Hi Nicholas,   Hope everything is going well.   Also, just checking to see how things are coming along with the information that you told us you would send to us this week.   Let us know if you have any questions.   Thanks Nicholas.   Have a great afternoon.   Mike     This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    RE: TracFone Audit Questions - Responses Inbox • Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Tue, Aug 30, 2016 at 1:29 PM Hi Mike – please see my responses to your questions inserted in bold blue font below.   If you would, please provide some timeframes in the near future that would be convenient for you for purposes of sitting down with us to discuss your audits.  For example, October 2016 would work for us, with the exception of October 6th.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.    From: TRS [mailto:crisp@trs-integrity.com]  Sent: Friday, August 26, 2016 4:43 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Thanks for the email regarding definitions.  After reviewing your definitions of the items below, we were wondering if the following are included in the revenue figures you sent to us?  As indicated in my prior e-mail communications, TracFone does not earn revenue in the City of Spokane, Washington.   All sales of the category 6102 "Pay as you Go" prepaid wireless services (airtime), voice and texting related to customers in the Spokane area. Yes. The sales of the category 6113 of Monthly Programs for prepaid wireless services (airtime), voice and texting related to customers in the Spokane area. Yes.   The sales of the category 6202 of BYOP related to customers in the Spokane area.  Yes.   And , if not, are part of these revenues included in the revenue figures that you sent to us?     We also need to see category 6308 revenues received for advertising (also include a copy of the contracts between ad sellers and TracFone) for advertising related to customers in the Spokane area.   Advertising sales arrangements take place at TracFone’s headquarters in Miami and have no connection to Spokane.    Thanks Nicholas.   Let us know if you have any questions.   Have a great day.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Wednesday, August 17, 2016 11:12 AM Subject: RE: TracFone Audit Questions - Responses   Hi Mike – please see below responses regarding your chart of accounts related questions.  Please be aware that I should have feedback related to your questions on the retail sales, wholesale sales and airtime revenue (where I had sent you some roughly estimated percentage amounts) next week sometime.     Account Number(s)                                                   Description   6102                                                    Airtime Revenue Ø  Sales of prepaid wireless service (airtime) of voice, data (internet), and texting under the “Pay as you go” or “PayGo” Airtime coverage, whereby minutes and days of service can be added as according to a customer’s needs.  Includes retail and wholesale sales (to retailers).   6112                                                    Revenue - TF Service Protection Ø  Sales of TF service protection plans, whereby customers can enroll and protect their service by receiving a 30-day service only extension if needed and add any airtime cards or minutes.   6113                                                    Revenue - Monthly Program Ø Sales of prepaid wireless service (airtime) of voice, data (internet), and texting under the monthly plans program.  For example, monthly plans of varying periods—of up to one year—are offered.   6118                                                    Revenue - Safelink Program Ø  The Lifeline service (“Safelink”) is a program that enables low-income households to afford phone service.  In the Safelink (Lifeline) Program, TracFone gives airtime (minutes) service free- of-charge to eligible, low-income participants.  In turn, TracFone receives payments, which are reimbursements by USAC for TracFone’s participation in the Safelink program.   6202                                                    BYOP Revenue Ø  Sales of TracFone BYOP packages, which include the BYOP SIM card.  BYOP stands for Bring Your Own Phone. With TracFone's Bring Your Own Phone program, a customer can get TracFone service on their current phone.       6303                                                    Revenue – Other Ø  Miscellaneous Revenue not related to operating activity.   6305                                                    Revenue - ILD Cards Ø  Sales of international long distance (“ILD”) prepaid wireless service (airtime) of voice, data (internet), and texting.   ILD makes it easy for wireless customers to make international calls.   6306                                                    Mobile Advertising Revenue Share Ø  Tracfone owns an inventory of “spaces” that its sells to ad networks (ad resellers). TracFone’s subscribers will see ads from several companies in apps, and then the ad networks will pay Tracfone for the use of these “spaces”.     6308                                                    Revenue - Advertising Ø  See 6306 above.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.        From: TRS [mailto:crisp@trs-integrity.com]  Sent: Monday, August 15, 2016 3:46 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nichols,   Hope things are going well with you and that things are starting to slow down.   Also, wanted to check and see how things are coming along with the information that we requested for the audit.   Let us know if you have any questions.   Thanks Nicholas.   Have a great afternoon.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Friday, August 5, 2016 7:35 AM Subject: RE: TracFone Audit Questions - Responses   Hi Mike – we’re just wrapping up our month end closing.  I had prepared a draft of responses to your questions and will circle back to my contact today, who was reviewing.   Thanks for your patience,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.        From: TRS [mailto:crisp@trs-integrity.com]  Sent: Thursday, August 04, 2016 6:02 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Just checking to see how things are coming along with the information that we requested on June 30th and April 29th.   Let us know if you have any questions.   Thanks Nicholas.   Have a great afternoon.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Thursday, July 28, 2016 5:00 PM Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Hope all is well with you.   I also wanted to check and see how things are coming along with the information that we requested for the audit.   Let us know if you have any questions.   Thanks Nicholas.   Have a great day.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Tuesday, July 19, 2016 2:40 PM Subject: RE: TracFone Audit Questions - Responses   Hi Mike – just a heads up that I’ve been working on your questions, however the Head of Tax and myself will be out of the office the rest of this week until Monday.  As such, I’d aim to get feedback to you sometime next week.   Thanks,     Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.        From: TRS [mailto:crisp@trs-integrity.com]  Sent: Tuesday, July 12, 2016 5:08 PM To: Nicholas Ford Subject: Fw: TracFone Audit Questions - Responses   Hi Nicholas,   Looking at our June 30 email below, we noticed that we made a typo of sorts. In item (3), we put the word "without," when we actually meant "with." Hopefully, from context, you caught our intended meaning and have been framing your reply accordingly, but just in case, we wanted to clarify.    Let us know if you have any questions.   Have a great day.   Thanks Nicholas.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Friday, July 8, 2016 2:01 PM Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Hope everything is going great for you.   Also, wanted to check and see how things are coming along with the email below and if you have any questions.   Thanks Nicholas.   Have a great weekend.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Thursday, June 30, 2016 4:08 PM Subject: Re: TracFone Audit Questions - Responses   Hi Nicolas,   Thanks for the information you sent. It is very helpful for us to understand the terminology used inside your company.   Regarding the calculations you sent us to back up the 30%, this is a good start, but we do have a few further questions.    1) If all of the Direct Sales Amount is "retail," and all of the Airtime Revenue is "wholesale," then, to find what percentage of total sales are Direct Sales, it looks like to me that we should add Direct and Airtime and divide Direct by the sum. Using this method, we arrive at 23.6% and 25.9%.   2) You are dividing two numbers, one is the Direct Sales Amount, and the other is the Airtime Revenue. We were wondering: are you dividing two things that are similar enough to compare? It seems that Direct Sales would include more than just airtime revenue, probably including handset sales and internet? So could you give a definition of each one, including what components they contain?   3) We were looking at the monthly reports you sent a while back, and the amounts from earlier years were so very much smaller than the amounts for more current years, yet company profits appeared high. Has the percentage of sales (comparing ones made without using another retailer to ones being done directly by TracFone) changed significantly over the years? At this point, it looks like we will need to see the figures used for calculating the percentages for each year, rather than just for a few recent years.  Could you send us this information?   Also, let us know if you have any questions concerning the April 29th email that we sent to you.   Thanks Nichols for all of your help.   Have a great 4th of July weekend.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Tuesday, June 28, 2016 12:25 PM Subject: RE: TracFone Audit Questions - Responses     Hi Mike – please see my responses below to your questions (per your 6/24 e-mail):   (1)   What is Internet (APP)?   Ø  The Alternative Payment Plan (“APP”) is TracFone’s credit card transaction interface for retail sales.  Under the APP, customers engage in one-time credit card based transactions via the internet or phone.   APP based customer transactions are consummated predominantly via the internet.  Furthermore, any TracFone plan program which is not available to be set up for an automated-recurring charge gets processed through APP.    (2) What is Billing Platform?   Ø The Billing Platform (“BP”) is a supplement to the Alternative Payment Plan (“APP”) to provide a system for automated-recurring charges.  Customers can make a one-time purchase or enroll into programs available for automated or recurring charges, most of which include airtime on a monthly (30 day) basis.    Based on the above, both APP and Billing Platform are internet-based credit card transaction interfaces for executing TracFone’s customers’ retail purchases—except that Billing Platform provides for recurring charges whereas APP allows customers to engaged in one-time credit card transactions.   (3)      Retail Sales Comprise Roughly 30% of TracFone’s sales.     Below shows the breakdown for 2013 and 2014, for example.     2013 Direct Sales Amounts (Per Accum. Summary Reports for '13)Company-Wide         1,658,066,825 31%Retail Sales Percentage Airtime Revenue (Per Financial Statements)Company-Wide      5,358,559,000 69% Wholesale Sales Percentage 2014 Direct Sales Amounts (Per Accum. Summary Reports for '14)Company-Wide         2,144,494,356 35%Retail Sales Percentage Airtime Revenue (Per Financial Statements)Company-Wide      6,126,893,000 65% Wholesale Sales Percentage   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.          From: TRS [mailto:crisp@trs-integrity.com]  Sent: Friday, June 24, 2016 4:35 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Thanks for your responses.  After reviewing your reports again we want to make sure we understand what each report is showing, so could you review with us the definition for each report below:   Platform report   APPT report   In other words, is the Billing Platform Report sales for website or phone sales or both?   And the APPT report sales would be for? The sheets say "internet," but we want to ascertain if this means that they were sales made over the internet, not sales of internet (data plans). Perhaps all of your sales are made in bundles, without breaking out data from telephone services?   In addition, do you have any back-up information for the 30 percent figure for your retail sales verses non-retail sales? We were wondering, as well, if this percent changed significantly over time?   Let us know, also, if you have any questions on the April 29 email.   Thanks Nicholas.   Have a great weekend.   Mike     This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Friday, June 24, 2016 8:06 AM Subject: RE: TracFone Audit Questions - Responses   Hi Mike – please see my responses to your questions below in bold blue font.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.  From: TRS [mailto:crisp@trs-integrity.com]  Sent: Tuesday, June 21, 2016 5:01 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Thanks for the email, and all the clarification you provided. We do appreciate it.   I was reviewing your answers to our questions below, and I noticed that you omitted one of the questions, the one asking for a percentage of revenues that come from other stores:   ". . . could you tell us the percentage of your revenues that come from your stores versus the revenues that come from other stores?"  As indicated my original response, TracFone is a reseller of prepaid wireless service (airtime) thatneither owns any stores nor cellular facilities.    Your answers below seem to indicate that both sales from other stores (which sales TracFone does not consider "retail"), and any recharges (or what TracFone calls "refills") associated with those sales, were not included in the figures you sent us. Please verify if this is the correct understanding.  Not correct:  TracFone does not own any stores.  Refills are retail sales of airtime.  As such, customers can purchase additional airtime (refills) via the internet (i.e., TracFone’s website), and over the phone.  Refills are included in the Billing Platform and Internet Sales retail sales summary reports/figures that I had sent to you.    So could you send us the percentage breakout between your sales at your Website and by phone (which we believe you call retail) and your other sales (non-"retail," including refills or what we call recharges on the non-retail sales)?   Retail sales comprise roughly 30% of TracFone’s sales.   Also, let me know if you have any questions concerning the email that we sent to you on April 29th, concerning other revenues that TracFone receives. Working on… Have a great afternoon.   Mike This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Friday, June 17, 2016 8:34 AM Subject: RE: TracFone Audit Questions - Responses   Hi Mike – please see responses below to your questions.  *Please note that I am still reviewing your questions related to TracFone’s chart of accounts.*   Billing Platform Transaction Detail Report:  What is?:  ·         OTAPURCH -- ‘over the air’ purchase of prepaid wireless services (airtime) by a customer through the phone. · Enrollment --  initial (one-time) enrollment of a customer when purchasing airtime.  · Recurring -- using the Billing Platform, customers make a one-time purchase or enroll into programs available for recurring charges, most of which include airtime on a monthly (30 day) basis.   · BN Enrollment – ‘Buy Now-Airtime on Demand’ enrollment’, which allows customers to choose and buy Airtime directly from their TracFone, so that they can buy Airtime when they need it.   Also, does TracFone receive their revenues for features such as call waiting sold to their customers, or are they part of the plan when you sell your cards?   No, TracFone does not receive revenues for call waiting.  The feature is part of the airtime plan that customers purchase, thus it is not a separate charge.   After thinking about it, we had some other questions.  You mentioned below that the data that you provided to us does not include retailers such as Walmart.  So the revenue figures that you sent to us are for your own stores?  First off, TracFone is a reseller of prepaid wireless service (airtime) that neither owns any stores nor cellular facilities.  It should also be noted that TracFone does not earn revenue in Burien, Federal Way, Kennewick, Renton, Spokane, or Tukwila.   As such, the Billing Platform, Internet Sales, and Telephone Sales excel format reports that you received comprise TracFone’s retail sales amounts.  These amounts, which are all of the Company’s retail sales, are from customer purchases made via the internet (i.e., the TracFone’s website) and over the phone.     Recharges on Sales Made by Outside Stores Such as Walmart:   One more question we forgot to ask you: when you send us the revenue information that we asked about in the email below, could you also include the charges to customers who have continued to use your services (directly through your drawing funds from their credit card or bank account) after they bought a phone or calling card from one of your outside retailers (like Walmart)? We generally refer to these charges as "recharges." Or are these charges included in the figures you already sent?  Refills of airtime that a customer can purchase at retail via the internet (i.e., the TracFone’s website), and over the phone.  They are included in the Billing Platform and Internet Sales retail reports that you received.   Recharges on Sales Made by TracFone's Own Stores:   In addition, we will need to ascertain that all recharges done on accounts opened at your own stores are included somewhere in the information we are provided with, as well: are charges (associated with sales that initiated at one of your stores) for continued services which were completed by automatic withdrawals or telephone withdrawals included in the figures you sent to us? If not, we will need access to these numbers as well.   See response to question above.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.      From: TRS [mailto:crisp@trs-integrity.com]  Sent: Friday, June 10, 2016 3:29 PM To: Nicholas Ford Subject: TracFone Audit   Hi Nicholas,   Hope everything is going well.   Also, just checking to see how things are coming along with the information that you told us you would send to us this week.   Let us know if you have any questions.   Thanks Nicholas.   Have a great afternoon.   Mike     This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.      RE: TracFone Audit Questions Inbox • Nicholas Ford <nford@tracfone.com> To:TRS Fri, Sep 30, 2016 at 1:52 PM   Hi Mike – here is an in part response below to your audit questions referenced in your latest e-mail:   Your Question:  “In the schedule grid below, and in your explanation, are we correct in understanding that the 'retail direct' figures contain phone and accessory revenue, but since these cannot be broken out (or can they?)”  Response:   Yes, the retail sales amounts contain phone and accessory revenue and they were broken out in separate files for each of the cities under audit—i.e., ‘telephone sales’.   You had received those files some time ago in separate e-mails.  For example, containing individual files for Billing Platform Sales, Internet Sales, and Telephone Sales.   *I expect to respond to the rest of your questions once my V.P. of Tax completes his review of the answers I’ve drafted and submitted to him.*   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.      From: TRS [mailto:crisp@trs-integrity.com]  Sent: Friday, September 23, 2016 4:53 PM To: Nicholas Ford Subject: TracFone Audit Questions Hi Nichols,   Just checking to see if you have had a chance to take a look at our questions below.   Thanks Nicholas.   Have a great weekend.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    ----- Forwarded Message ----- From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Wednesday, September 7, 2016 2:09 PM Subject: RE: TracFone Audit Questions - Responses   Hello Mike – I’ll be out of the office beginning tomorrow (9/8) and returning on Monday (9/12), at which time I can take a closer look at your questions below.   Thanks,     Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.      From: TRS [mailto:crisp@trs-integrity.com]  Sent: Wednesday, September 07, 2016 4:49 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Hope you had a great holiday weekend.   Thanks for all of the information sent August 26. After studying the figures, we have some questions. In the schedule grid below, and in your explanation, are we correct in understanding that the 'retail direct' figures contain phone and accessory revenue, but since these cannot be broken out (or can they?), and since the net airtime revenue did not contain phones and accessories, you found the total phone and accessory revenue and added that into the net airtime figures, then you used this sum to come up with the percentages?   If so, this is very helpful. Now, looking at the chart you sent to us on August 17 (copied below), I am wondering how close we have come in comparing like figures to come up with percentages. Which of the revenue code categories below are included in the the Airtime revenue values you sent August 26th? And which are included in the Retail Direct revenue values sent August 26th? I know the retail direct section is labeled "airtime and phones," but, for example, there is airtime in the monthly program, but only Category 6102 is named "Airtime Revenue."   6102                                                    Airtime Revenue Ø  Sales of prepaid wireless service (airtime) of voice, data (internet), and texting under the “Pay as you go” or “PayGo” Airtime coverage, whereby minutes and days of service can be added as according to a customer’s needs.  Includes retail and wholesale sales (to retailers). 6112                                                    Revenue - TF Service Protection Ø  Sales of TF service protection plans, whereby customers can enroll and protect their service by receiving a 30-day service only extension if needed and add any airtime cards or minutes. 6113                                                    Revenue - Monthly Program Ø  Sales of prepaid wireless service (airtime) of voice, data (internet), and texting under the monthly plans program.  For example, monthly plans of varying periods—of up to one year—are offered. 6118                                                    Revenue - Safelink Program Ø  The Lifeline service (“Safelink”) is a program that enables low-income households to afford phone service.  In the Safelink (Lifeline) Program, TracFone gives airtime (minutes) service free-of-charge to eligible, low-income participants.  In turn, TracFone receives payments, which are reimbursements by USAC for TracFone’s participation in the Safelink program. 6202                                                    BYOP Revenue Ø  Sales of TracFone BYOP packages, which include the BYOP SIM card.  BYOP stands for Bring Your Own Phone. With TracFone's Bring Your Own Phone program, a customer can get TracFone service on their current phone.       6303                                                    Revenue – Other Ø  Miscellaneous Revenue not related to operating activity. 6305                                                    Revenue - ILD Cards Ø  Sales of international long distance (“ILD”) prepaid wireless service (airtime) of voice, data (internet), and texting.   ILD makes it easy for wireless customers to make international calls. 6306                                                    Mobile Advertising Revenue Share Ø  Tracfone owns an inventory of “spaces” that its sells to ad networks (ad resellers). TracFone’s subscribers will see ads from several companies in apps, and then the ad networks will pay Tracfone for the use of these “spaces”.   6308                                                    Revenue - Advertising Ø  See 6306 above.   Also, you stated that you have the ability to break out the interstate information. At what level(s) can you do this, city, state, national or company-wide?    Thanks Nicolas.   Have a great afternoon.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Friday, August 26, 2016 10:35 AM Subject: RE: TracFone Audit Questions - Responses   Hi Mike – in regard to your remaining questions, please see responses below.  As far as I can tell, in providing the information below there are no outstanding questions and/or requests for other information.  Assuming that’s the case, we are asking once again for an opportunity to meet with you—as we also requested in December 2014 to meet in January 2015—and discuss your WA local/city audits with the aim of bringing them to a resolution.  If you would, please provide some timeframes in the near future that would be convenient for you for purposes of sitting down with us to discuss your audits.  For example, October 2016 would work for us, with the exception of October 6th.   1) Your Question:  If all of the Direct Sales Amount is "retail," and all of the Airtime Revenue is "wholesale," then, to find what percentage of total sales are Direct Sales, it looks like to me that we should add Direct and Airtime and divide Direct by the sum. Using this method, we arrive at 23.6% and 25.9%. Ø   Response:  The roughly 30% (retail-direct) sales compared to the roughly 70% wholesale was just that—an estimate.  It was also based on the whole company as opposed to a particular state or city.  The net airtime revenue (per financial statements) denominator includes not only retail sales, but also wholesale sales.    2) Your Question: You are dividing two numbers, one is the Direct Sales Amount, and the other is the Airtime Revenue. We were wondering: are you dividing two things that are similar enough to compare? It seems that Direct Sales would include more than just airtime revenue, probably including handset sales and internet? So could you give a definition of each one, including what components they contain? Ø  Response:  In addition to the net airtime revenue (per financial statements) denominator, the grid below now shows a separate break-out of sales of phones & accessories sales.  The retail sales amounts (numerator) that were provided to you also include both phones & accessories sales and internet.    3) Your Question:  We were looking at the monthly reports you sent a while back, and the amounts from earlier years were so very much smaller than  the amounts for more current years, yet company profits appeared high. Has the percentage of sales (comparing ones made without using another retailer to ones being done directly by TracFone) changed significantly over the years? At this point, it looks like we will need to see the figures used for calculating the percentages for each year, rather than just for a few recent years.  Could you send us this information?    Ø  Response:  See information in schedule grid below, which serves as a basis for the estimated wholesale percentages shown.    2010 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                           486,626,850 17%Retail Sales Percentage (2) Net Airtime Revenue (Per Financial Statements)                                 2,457,761,508 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                            341,243,351 Total (2) + (3):                                 2,799,004,859  Company-Wide 1 minus Retail Percentage =83% Wholesale Sales Percentage 2011 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                           793,674,906 21%Retail Sales Percentage (2) Net Airtime Revenue (Per Financial Statements)                                 3,433,624,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                            380,952,000 Total (2) + (3):                                 3,814,576,000    Company-Wide 1 - Retail Percentage =79% Wholesale Sales Percentage 2012 (1) Retail (Direct) Sales Amounts (Airtime & Phones)Company-Wide                                                                 1,164,915,001 24%Retail Sales Percentage (2) Net Airtime Revenue (Per Financial Statements)                                 4,291,440,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                            502,534,000 Total (2) + (3):                                 4,793,974,000    Company-Wide 1 - Retail Percentage =76% Wholesale Sales Percentage 2013 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 1,658,066,825 27%Retail Sales Percentage (2) Net Airtime Revenue (Per Financial Statements)                                 5,358,599,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                            676,091,000 Total (2) + (3):                                 6,034,690,000    Company-Wide 1 - Retail Percentage =73% Wholesale Sales Percentage 2014 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 2,144,494,356 31%Retail Sales Percentage (2) Net Airtime Revenue (Per Financial Statements)                                 6,126,893,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                            694,099,000 Total (2) + (3):                                 6,820,992,000    Company-Wide 1 - Retail Percentage =69% Wholesale Sales Percentage 2015 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 2,330,936,554 33%Retail Sales Percentage (2) Net Airtime Revenue (Per Financial Statements)                                 6,279,204,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                            699,462,000 Total (2) + (3):                                 6,978,666,000    Company-Wide 1 - Retail Percentage =67% Wholesale Sales Percentage   4) Your Question:  We need to know if you would be able to break out the interstate amounts for the long-distance charges. Ø  Response:  we have the ability to identify interstate amounts for total calling activity.      Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.    From: TRS [mailto:crisp@trs-integrity.com]  Sent: Wednesday, August 17, 2016 5:01 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Thanks Nicholas.  We will review the information that you sent to us and we will let you know if we have any questions.   Have a great afternoon.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Wednesday, August 17, 2016 11:12 AM Subject: RE: TracFone Audit Questions - Responses     Hi Mike – please see below responses regarding your chart of accounts related questions.  Please be aware that I should have feedback related to your questions on the retail sales, wholesale sales and airtime revenue (where I had sent you some roughly estimated percentage amounts) next week sometime.     Account Number(s)                                                   Description   6102                                                    Airtime Revenue Ø  Sales of prepaid wireless service (airtime) of voice, data (internet), and texting under the “Pay as you go” or “PayGo” Airtime coverage, whereby minutes and days of service can be added as according to a customer’s needs.  Includes retail and wholesale sales (to retailers).   6112                                                    Revenue - TF Service Protection Ø  Sales of TF service protection plans, whereby customers can enroll and protect their service by receiving a 30-day service only extension if needed and add any airtime cards or minutes.   6113                                                    Revenue - Monthly Program Ø  Sales of prepaid wireless service (airtime) of voice, data (internet), and texting under the monthly plans program.  For example, monthly plans of varying periods—of up to one year—are offered.   6118                                                    Revenue - Safelink Program Ø  The Lifeline service (“Safelink”) is a program that enables low-income households to afford phone service.  In the Safelink (Lifeline) Program, TracFone gives airtime (minutes) service free- of-charge to eligible, low-income participants.  In turn, TracFone receives payments, which are reimbursements by USAC for TracFone’s participation in the Safelink program.   6202                                                    BYOP Revenue Ø  Sales of TracFone BYOP packages, which include the BYOP SIM card.  BYOP stands for Bring Your Own Phone. With TracFone's Bring Your Own Phone program, a customer can get TracFone service on their current phone.       6303                                                    Revenue – Other Ø  Miscellaneous Revenue not related to operating activity.   6305                                                    Revenue - ILD Cards Ø  Sales of international long distance (“ILD”) prepaid wireless service (airtime) of voice, data (internet), and texting.   ILD makes it easy for wireless customers to make international calls.   6306                                                    Mobile Advertising Revenue Share Ø  Tracfone owns an inventory of “spaces” that its sells to ad networks (ad resellers). TracFone’s subscribers will see ads from several companies in apps, and then the ad networks will pay Tracfone for the use of these “spaces”.     6308                                                    Revenue - Advertising Ø  See 6306 above.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.  From: TRS [mailto:crisp@trs-integrity.com]  Sent: Monday, August 15, 2016 3:46 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nichols,   Hope things are going well with you and that things are starting to slow down.   Also, wanted to check and see how things are coming along with the information that we requested for the audit.   Let us know if you have any questions.   Thanks Nicholas.   Have a great afternoon.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Friday, August 5, 2016 7:35 AM Subject: RE: TracFone Audit Questions - Responses Hi Mike – we’re just wrapping up our month end closing.  I had prepared a draft of responses to your questions and will circle back to my contact today, who was reviewing.   Thanks for your patience,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.        From: TRS [mailto:crisp@trs-integrity.com]  Sent: Thursday, August 04, 2016 6:02 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Just checking to see how things are coming along with the information that we requested on June 30th and April 29th.   Let us know if you have any questions.   Thanks Nicholas.   Have a great afternoon.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Thursday, July 28, 2016 5:00 PM Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Hope all is well with you.   I also wanted to check and see how things are coming along with the information that we requested for the audit.   Let us know if you have any questions.   Thanks Nicholas.   Have a great day.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Tuesday, July 19, 2016 2:40 PM Subject: RE: TracFone Audit Questions - Responses   Hi Mike – just a heads up that I’ve been working on your questions, however the Head of Tax and myself will be out of the office the rest of this week until Monday.  As such, I’d aim to get feedback to you sometime next week.   Thanks,     Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.        From: TRS [mailto:crisp@trs-integrity.com]  Sent: Tuesday, July 12, 2016 5:08 PM To: Nicholas Ford Subject: Fw: TracFone Audit Questions - Responses   Hi Nicholas,   Looking at our June 30 email below, we noticed that we made a typo of sorts. In item (3), we put the word "without," when we actually meant "with." Hopefully, from context, you caught our intended meaning and have been framing your reply accordingly, but just in case, we wanted to clarify.    Let us know if you have any questions.   Have a great day.   Thanks Nicholas.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Friday, July 8, 2016 2:01 PM Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Hope everything is going great for you.   Also, wanted to check and see how things are coming along with the email below and if you have any questions.   Thanks Nicholas.   Have a great weekend.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Thursday, June 30, 2016 4:08 PM Subject: Re: TracFone Audit Questions - Responses   Hi Nicolas,   Thanks for the information you sent. It is very helpful for us to understand the terminology used inside your company.   Regarding the calculations you sent us to back up the 30%, this is a good start, but we do have a few further questions.    1) If all of the Direct Sales Amount is "retail," and all of the Airtime Revenue is "wholesale," then, to find what percentage of total sales are Direct Sales, it looks like to me that we should add Direct and Airtime and divide Direct by the sum. Using this method, we arrive at 23.6% and 25.9%.   2) You are dividing two numbers, one is the Direct Sales Amount, and the other is the Airtime Revenue. We were wondering: are you dividing two things that are similar enough to compare? It seems that Direct Sales would include more than just airtime revenue, probably including handset sales and internet? So could you give a definition of each one, including what components they contain?   3) We were looking at the monthly reports you sent a while back, and the amounts from earlier years were so very much smaller than the amounts for more current years, yet company profits appeared high. Has the percentage of sales (comparing ones made without using another retailer to ones being done directly by TracFone) changed significantly over the years? At this point, it looks like we will need to see the figures used for calculating the percentages for each year, rather than just for a few recent years.  Could you send us this information?   Also, let us know if you have any questions concerning the April 29th email that we sent to you.   Thanks Nichols for all of your help.   Have a great 4th of July weekend.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Tuesday, June 28, 2016 12:25 PM Subject: RE: TracFone Audit Questions - Responses     Hi Mike – please see my responses below to your questions (per your 6/24 e-mail):   (1)   What is Internet (APP)?   Ø  The Alternative Payment Plan (“APP”) is TracFone’s credit card transaction interface for retail sales.  Under the APP, customers engage in one-time credit card based transactions via the internet or phone.   APP based customer transactions are consummated predominantly via the internet.  Furthermore, any TracFone plan program which is not available to be set up for an automated-recurring charge gets processed through APP.    (2)    What is Billing Platform?   Ø  The Billing Platform (“BP”) is a supplement to the Alternative Payment Plan (“APP”) to provide a system for automated-recurring charges.  Customers can make a one-time purchase or enroll into programs available for automated or recurring charges, most of which include airtime on a monthly (30 day) basis.    Based on the above, both APP and Billing Platform are internet-based credit card transaction interfaces for executing TracFone’s customers’ retail purchases—except that Billing Platform provides for recurring charges whereas APP allows customers to engaged in one-time credit card transactions.   (3)      Retail Sales Comprise Roughly 30% of TracFone’s sales.     Below shows the breakdown for 2013 and 2014, for example.     2013 Direct Sales Amounts (Per Accum. Summary Reports for '13)Company-Wide         1,658,066,825   31%Retail Sales Percentage Airtime Revenue (Per Financial Statements)Company-Wide      5,358,559,000  69% Wholesale Sales Percentage 2014 Direct Sales Amounts (Per Accum. Summary Reports for '14)Company-Wide         2,144,494,356   35%Retail Sales Percentage Airtime Revenue (Per Financial Statements)Company-Wide      6,126,893,000  65% Wholesale Sales Percentage   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.          From: TRS [mailto:crisp@trs-integrity.com]  Sent: Friday, June 24, 2016 4:35 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Thanks for your responses.  After reviewing your reports again we want to make sure we understand what each report is showing, so could you review with us the definition for each report below:   Platform report   APPT report   In other words, is the Billing Platform Report sales for website or phone sales or both?   And the APPT report sales would be for? The sheets say "internet," but we want to ascertain if this means that they were sales made over the internet, not sales of internet (data plans). Perhaps all of your sales are made in bundles, without breaking out data from telephone services?   In addition, do you have any back-up information for the 30 percent figure for your retail sales verses non-retail sales? We were wondering, as well, if this percent changed significantly over time?   Let us know, also, if you have any questions on the April 29 email.   Thanks Nicholas.   Have a great weekend.   Mike     This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Friday, June 24, 2016 8:06 AM Subject: RE: TracFone Audit Questions - Responses     Hi Mike – please see my responses to your questions below in bold blue font.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.          From: TRS [mailto:crisp@trs-integrity.com]  Sent: Tuesday, June 21, 2016 5:01 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Thanks for the email, and all the clarification you provided. We do appreciate it.   I was reviewing your answers to our questions below, and I noticed that you omitted one of the questions, the one asking for a percentage of revenues that come from other stores: ". . . could you tell us the percentage of your revenues that come from your stores versus the revenues that come from other stores?"  As indicated my original response, TracFone is a reseller of prepaid wireless service (airtime) that neither owns any stores nor cellular facilities.  Your answers below seem to indicate that both sales from other stores (which sales TracFone does not consider "retail"), and any recharges (or what TracFone calls "refills") associated with those sales, were not included in the figures you sent us. Please verify if this is the correct understanding.  Not correct:  TracFone does not own any stores.  Refills are retail sales of airtime.  As such, customers can purchase additional airtime (refills) via the internet (i.e., TracFone’s website), and over the phone.  Refills are included in the Billing Platform and Internet Sales retail sales summary reports/figures that I had sent to you.    So could you send us the percentage breakout between your sales at your Website and by phone (which we believe you call retail) and your other sales (non-"retail," including refills or what we call recharges on the non-retail sales)?   Retail sales comprise roughly 30% of TracFone’s sales. Also, let me know if you have any questions concerning the email that we sent to you on April 29th, concerning other revenues that TracFone receives.Working on… Have a great afternoon.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Friday, June 17, 2016 8:34 AM Subject: RE: TracFone Audit Questions - Responses     Hi Mike – please see responses below to your questions.  *Please note that I am still reviewing your questions related to TracFone’s chart of accounts.*   Billing Platform Transaction Detail Report:  What is?:  ·         OTAPURCH -- ‘over the air’ purchase of prepaid wireless services (airtime) by a customer through the phone. ·         Enrollment --  initial (one-time) enrollment of a customer when purchasing airtime.  ·         Recurring -- using the Billing Platform, customers make a one-time purchase or enroll into programs available for recurring charges, most of which include airtime on a monthly (30 day) basis.   ·         BN Enrollment – ‘Buy Now-Airtime on Demand’ enrollment’, which allows customers to choose and buy Airtime directly from their TracFone, so that they can buy Airtime when they need it.   Also, does TracFone receive their revenues for features such as call waiting sold to their customers, or are they part of the plan when you sell your cards?   No, TracFone does not receive revenues for call waiting.  The feature is part of the airtime plan that customers purchase, thus it is not a separate charge.   After thinking about it, we had some other questions.  You mentioned below that the data that you provided to us does not include retailers such as Walmart.  So the revenue figures that you sent to us are for your own stores?  First off, TracFone is a reseller of prepaid wireless service (airtime) that neither owns any stores nor cellular facilities.  It should also be noted that TracFone does not earn revenue in Burien, Federal Way, Kennewick, Renton, Spokane, or Tukwila.   As such, the Billing Platform, Internet Sales, and Telephone Sales excel format reports that you received comprise TracFone’s retail sales amounts.  These amounts, which are all of the Company’s retail sales, are from customer purchases made via the internet (i.e., the TracFone’s website) and over the phone.     Recharges on Sales Made by Outside Stores Such as Walmart:   One more question we forgot to ask you: when you send us the revenue information that we asked about in the email below, could you also include the charges to customers who have continued to use your services (directly through your drawing funds from their credit card or bank account) after they bought a phone or calling card from one of your outside retailers (like Walmart)? We generally refer to these charges as "recharges." Or are these charges included in the figures you already sent?  Refills of airtime that a customer can purchase at retail via the internet (i.e., the TracFone’s website), and over the phone.  They are included in the Billing Platform and Internet Sales retail reports that you received.   Recharges on Sales Made by TracFone's Own Stores:   In addition, we will need to ascertain that all recharges done on accounts opened at your own stores are included somewhere in the information we are provided with, as well: are charges (associated with sales that initiated at one of your stores) for continued services which were completed by automatic withdrawals or telephone withdrawals included in the figures you sent to us? If not, we will need access to these numbers as well.   See response to question above.   Thanks,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.  From: TRS [mailto:crisp@trs-integrity.com]  Sent: Friday, June 10, 2016 3:29 PM To: Nicholas Ford Subject: TracFone Audit   Hi Nicholas,   Hope everything is going well. Also, just checking to see how things are coming along with the information that you told us you would send to us this week.   Let us know if you have any questions.   Thanks Nicholas.   Have a great afternoon.   Mike This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.    Re: TracFone Audit Questions Sent • TRS <crisp@trs-integrity.com> To:Nicholas Ford Fri, Sep 30, 2016 at 3:50 PM Hi Nicolas, Thanks for the response.  But the question we were asking was regarding the schedule you sent detailing the company-wide data and calculated percents (not the city-specific data). Could you take another look at the question in reference to the company-wide data on the schedule that you sent to us?  Thanks Nicolas. Have a great weekend. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  NOTE: Email train omitted, as it is the same as the email and train above, same date and subject. TracFone Audit Questions Sent • TRS <crisp@trs-integrity.com> To:Nicholas Ford Fri, Oct 7, 2016 at 2:53 PM Hi Nicholas, Hope all is well with you. Also, just checking to see if you have had a chance to take a look at the email below and how things are coming along with the other information that you were going to send us. Let us know if you have any questions. Thanks Nicholas. Have a great weekend. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Friday, September 30, 2016 3:50 PM Subject: Re: TracFone Audit Questions Hi Nicolas, Thanks for the response.  But the question we were asking was regarding the schedule you sent detailing the company-wide data and calculated percents (not the city-specific data). Could you take another look at the question in reference to the company-wide data on the schedule that you sent to us?  Thanks Nicolas. Have a great weekend. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  NOTE: the rest of this email train is omitted because it is the same as the last two emails on this sheet. TracFone Audit Questions Sent • TRS <crisp@trs-integrity.com> To:Nicholas Ford Fri, Oct 28, 2016 at 5:14 PM Hi Nicholas, Just checking to see if you have had a chance to look at the email below. Let us know if you have any questions. Thanks Nicholas. Have a great weekend. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  ----- Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Monday, October 17, 2016 2:12 PM Subject: Re: TracFone Audit Questions Hi Nicholas, Thanks for the chart below. Assuming that the answers you provided are for the company-wide date figures, it does look as though we are pretty much comparing like numbers; we know the Safelink program represents a tiny proportion of revenues, and other than that, the figures contain the same elements. But here are some outstanding questions:  -You told us in an earlier email that phones could be broken out of the conglomerate numbers you sent. Why did you add phones in one rather than removing them from the other? How difficult would that be to convert these to non-accessary numbers? That would be a bit more accurate, but for estimation purposes, we could also assume that the percentages would be the same for both. -Have you any more information on how to break out intrastate and interstate calls? -Can you verify for us that the answers in the chart below (October 10) refer to the company-wide figures supplied to us on August 26th? Thanks, Nicholas. We really appreciate all your work on this. Have a great afternoon. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  NOTE: This email train is truncated because it is repeated above. Same subject line. Net vs Gross Sent • TRS <crisp@trs-integrity.com> To:Nicholas Ford Tue, Feb 21, 2017 at 2:08 PM Hi Nicholas, Hope everything is going well. Just checking to see if you have had a chance to review the questions below. Let us know if you have any questions. Thanks Nicholas. Have a great afternoon. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com>  Sent: Thursday, February 9, 2017 2:32 PM Subject: Re: Net vs Gross Thanks, Nicholas, for the information.  We do appreciate all of your help with these audits. We will be looking forward to the before-2010 figures regarding the whole-company data. Could you also provide a more direct answer to that part of the first question regarding "gross" and "net," that reads, "And were the figures for direct sales, which are not labeled "net," inclusive of the types of revenue excluded in these numbers? If so, is there any way of correcting this situation with a percentage of "net" vs "gross" ?" Once again, here we were wondering if your numbers for city-wide sales included the same part of revenues as the company-wide sales. Are they different? And if so, what is the percentage of difference? As soon as we wrap up the audits, we can then discuss the matter with the [city] about your concerns and how they would like to move forward.  As you probably remember, the [city has] asked us to complete the audits before they would consider your request regarding any meetings. And as mentioned before, we do not plan to send out any assessments before you have had a chance to take a look at our audit schedules. Regarding Burien, we only have numbers going back as far as 2009 for the city-specific data. The audit date for this begins with 2003. Should we estimate these figures, or are you also working on obtaining this data? Thanks, and have a great day. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Thursday, February 9, 2017 10:47 AM Subject: RE: Net vs Gross Hi Mike – please see my responses to your questions bolded in green font below.   As discussed, from our end it would be preferable to enlighten you on our business model and answer your questions in-person.   The sit down does not have to be formal in order to walk you through the workings of our business.   Regards,   Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.    From: TRS [mailto:crisp@trs-integrity.com]  Sent: Monday, January 09, 2017 5:00 PM To: Nicholas Ford Subject: Net vs Gross   Hi Nicholas, Hope you had a Happy New Year Day.   We are working on the audit tax schedules, and have 3 questions for you: 1. While working on the audit estimate spreadsheets, we noticed something that we had missed earlier. The first chart you sent to us in June showing company-wide direct sales vs. airtime revenue just labeled the airtime revenue without inserting the word "net." But the chart you sent us in August, which showed the same and additional numbers, inserted a further clarification by labeling direct airtime and phone accessories as "net."    Since these numbers are net and not gross, can you explain what was excluded from the gross to make them net? And were the figures for direct sales, which are not labeled "net," inclusive of the types of revenue excluded in these numbers? If so, is there any way of correcting this situation with a percentage of "net" vs "gross" ?   there is a revenue recognition concept involved, whereby some there are things such as deferrals, etc which are not a part of net revenue.   Net revenue is basically recognized revenue.   2. Another question. In graphing the percents of indirect vs. direct sales, we noticed a big drop between 2010 and 2011. Not sure what you mean by ‘big drop’, based on the retail vs wholesale percentages provided from 2010 to 2011 – i.e., 2010: 17% (retail), 83% (wholesale); 2011: 21% (retail), 79% (wholesale).   Was there a point when TracFone did 100% indirect sales? If so, when did that change? We are trying to figure a good way to estimate for the time before your data begins. We don't have indirect vs direct figures for earlier than 2010. Can you get those for us quickly, or should we work toward an educated estimate for this?   I’ll be working on compiling retail vs wholesale figures for earlier than 2010, and seek to provide at my earliest.   3. The direct sales data years you gave us does not always correlate with the audit period. With your permission, we can expand the audit to match the direct-sales information you have given us, and estimate the years of the audit for years you have not. Another option would be to take the audit up to the present, although this would require either more data or some additional estimation. Another option is to include only the years open on the audit, which would require another audit to be opened to bring you up to the present. Whatever you want to do is your choice and we will go with it. Let us know what way you would think would be best.  I do not give permission to alter the audit periods.  Thanks, Nicolas.   Let us know if you have any questions.   Have a great afternoon.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  Net/Gross question and information for the City of Burien Sent • TRS <crisp@trs-integrity.com> To:Nicholas Ford Tue, Mar 28, 2017 at 1:59 PM Hi Nichols, Hope all is going well. Just checking to see how things are coming along with our net/gross questions. Also, are you going to be able to provide more information for us for the City of Burien, or is the year 2008 is the furthest that you can go back? Let us know if you have any questions. Thanks Nicholas. Have a great day. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  Re: Missing Billing Platform Sales Sent • TRS <crisp@trs-integrity.com> To:Nicholas Ford Thu, May 11, 2017 at 11:44 AM Hi Nicholas, We were wondering about when the data shows that no Billing Platform or Western Union sales are completed in a city: can you tell us what is happening in that situation?  Where all direct sales done APP at that time? It looked particularly strange in the case of Burien 7/07, which had Billing Platform sales the month before and none that month, but we looked more closely, and there are two submittals for that month, one with Billing Platform, and one without, so that's all good. Thanks Nicholas, and we will be looking forward to the Renton information you will be sending today. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Thursday, May 11, 2017 7:14 AM Subject: RE: Missing Billing Platform Sales Hi Mike – see below   ·         Billing Platform was not in existence as a customer retail sales transaction interface until May 2007.  As such, there are no Billing Platform sales for Burien in 2006 (i.e., 4/06—12/06) or 2007 (i.e., 1/07—4/07).  For May 2007, there were no Billing Platform sales for Burien and thus you did not receive a file.   Please check your e-mail on May 2ndfor the Burien Billing Platform file for July 2007 that I sent you.     ·         Prior to the existence of the Billing Platform customer retail sales transaction interface, Western Union was being used (as well as APP) for retail sales of airtime.  And you are not correct to say that Western Union was the Billing Platform.   ·         Per my 1st bullet point, Billing Platform was not in existence to record retail sales transactions during the 1/07—4/07 period.   For May 2007, there were no Billing Platform sales for Renton.  However, I will be sending you today the Billing Platform retail sales reports for Renton for 6/07—12/07.   You can let me know if you are missing anything else.   Thanks,     Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.  From: TRS [mailto:crisp@trs-integrity.com]  Sent: Wednesday, May 10, 2017 7:38 PM To: Nicholas Ford Subject: Missing Billing Platform Sales Hi Nicholas, After reviewing the information we noticed that we are missing the Billing Platform sales for Burien: 4/06 through 12/06; 1/07 through 5/07; and 7/07. Are we correct in assuming that Western Union was the billing sales of 1/06 through 3/06? We are also missing Billing Platform sales, as you know, for Renton for all of 2007. Will you be able to get these to us right away, or will we need to estimate them?  Thanks Nicholas for checking this out for us. Have a great day.   Mike This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it. Re: Missing Billing Platform Sales Sent • TRS <crisp@trs-integrity.com> To:Nicholas Ford Thu, May 11, 2017 at 11:44 AM Hi Nicholas, We were wondering about when the data shows that no Billing Platform or Western Union sales are completed in a city: can you tell us what is happening in that situation?  Where all direct sales done APP at that time? It looked particularly strange in the case of Burien 7/07, which had Billing Platform sales the month before and none that month, but we looked more closely, and there are two submittals for that month, one with Billing Platform, and one without, so that's all good. Thanks Nicholas, and we will be looking forward to the Renton information you will be sending today. Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Thursday, May 11, 2017 7:14 AM Subject: RE: Missing Billing Platform Sales Hi Mike – see below   ·         Billing Platform was not in existence as a customer retail sales transaction interface until May 2007.  As such, there are no Billing Platform sales for Burien in 2006 (i.e., 4/06—12/06) or 2007 (i.e., 1/07—4/07).  For May 2007, there were no Billing Platform sales for Burien and thus you did not receive a file.   Please check your e-mail on May 2ndfor the Burien Billing Platform file for July 2007 that I sent you.     ·         Prior to the existence of the Billing Platform customer retail sales transaction interface, Western Union was being used (as well as APP) for retail sales of airtime.  And you are not correct to say that Western Union was the Billing Platform.   ·         Per my 1st bullet point, Billing Platform was not in existence to record retail sales transactions during the 1/07—4/07 period.   For May 2007, there were no Billing Platform sales for Renton.  However, I will be sending you today the Billing Platform retail sales reports for Renton for 6/07—12/07.   You can let me know if you are missing anything else.   Thanks,     Nicholas E. Ford | Corporate Tax  | TracFone Wireless, Inc. | O: 305.715.6500 extn. 3217 |  nford@TracFone.com _______________________________________________________________ This Email contains PRIVILEGED AND CONFIDENTIAL, PROPRIETARY INFORMATION intended only for the use of the Addressee(s) named above.        From: TRS [mailto:crisp@trs-integrity.com]  Sent: Wednesday, May 10, 2017 7:38 PM To: Nicholas Ford Subject: Missing Billing Platform Sales   Hi Nicholas,   After reviewing the information we noticed that we are missing the Billing Platform sales for Burien: 4/06 through 12/06; 1/07 through 5/07; and 7/07. Are we correct in assuming that Western Union was the billing sales of 1/06 through 3/06? We are also missing Billing Platform sales, as you know, for Renton for all of 2007. Will you be able to get these to us right away, or will we need to estimate them?    Thanks Nicholas for checking this out for us. Have a great day.   Mike   This email and any files attached to it are the property of Tax Recovery Services, LLC. The contents may be confidential and proprietary, and any use or distribution of the information contained herein may be prohibited by law. If you are not a named recipient, or if you have received this email in error, please notify the person who sent it, and immediately delete it.  •