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HomeMy WebLinkAboutExhibit 63 Remake-2Remake of Exhibit 63; Section 2 TracFone - TRS Emails Renton TracFone Audit TracFone audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Mon, Mar 9, 2015 at 4:26 PM Hi Nicholas, Hope everything is going well for you. We have had a chance to review the TracFone audit with the various cities and legal counsel on how they would like us to move forward with the audit.  Each city has informed us that they would like us to receive the information that was requested for the audit before meeting with your attorney.   Your company has the legal obligation to open your books, supply the information we request, and let us perform an audit.  If after  the information that was requested has been forthcoming, and we have had a chance to examine the information, then you will have your chance to present us with any unique situations you believe may exist concerning your business.  If you have any questions on what was requested for the audit, let us know, and we would be glad to clarify what is needed. Thanks Nicholas. Mlke    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.  TracFone audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, May 13, 2015 at 2:55 PM Hi Nicholas, Hope things have been going well with you. We received a telephone call from your office, but no one left a message.  Did you have some questions concerning the subpoenas or concerning what information we need to conduct the audit?  If you do , could you send them by email.   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. TracFone-Washington State City Audits -- Question Regarding Data Request Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Fri, May 29, 2015 at 8:36 AM Hi Mike – I have a question related to your list of requested items in Exhibit A for the respective cities under audit.  Specifically, it is to be noted that TracFone does not bill or invoice its customers.  As such, please clarify your request for invoices for customers in the cities under audit for the stated sample periods.      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-Washington State City Audits-- Question Regarding Data Request Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, May 29, 2015 at 2:40 PM Hi Nicholas, Good to hear from you. Do you have any record at all that shows how the customer is charged and what they are charged? How does your customer know what he is being billed?  The reason why we need this information is to show what revenues are taxable and what revenues would not be taxable.  Can you show us how you calculate (and on what amounts you calculate) FCC fees, regulatory fees and such for the customer?  Or if you do it in aggregate, show us how this is done. So if you do not do individual invoices, give us revenue information at a higher level that shows the same break out of fees and taxes that could then be broken down (by division) to approximate the individual invoices. If you have the number of sales per month for those months, that would be good, as we could divide by that amount to approximate invoices. Since in the court case with the State of Washington and TracFone, where the issue was with the 911 charge, TracFone is required to calculate these fees for Washington State, there must be some type of break out for Washington State for calculating the 911 charge. It seems that a sourcing of sorts would be necessary for this.  And the Washington State tax return would also be a good starting point for coming up with these estimates. Please send us what information you have on these issues so that we can calculate as closely as possible what the cities would believe is taxable. Thanks Nicholas. Let me know if you have any other questions.   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, May 29, 2015 8:32 AM Subject: TracFone-Washington State City Audits -- Question Regarding Data Request Hi Mike – I have a question related to your list of requested items in Exhibit A for the respective cities under audit.  Specifically, it is to be noted that TracFone does not bill or invoice its customers.  As such, please clarify your request for invoices for customers in the cities under audit for the stated sample periods.      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 audits Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Wed, Jun 3, 2015 at 1:40 PM Hi Mike – in regard to the TRS-TracFone WA local cities audits, it appears that there may be overlapping zip codes among each of the cities under audit.   For each of the cities listed in your e-mail below I am hoping that you could specify the zip codes that are exclusive to each of the cities under audit so that we can respond to your data requests.    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 02, 2015 3:59 PM To: Nicholas Ford Subject: TracFone audits   Hi Nicholas,   Good talking with you today.  We doubled checked our records and turns out that the City of Tukwila was also one of the auditing cities.  All of the cities together are:  City of Spokane, City of Renton, City of Burien, City of Federal Way, City of Kennewick and the City of Tukwila.   Let us know if you have any questions.    Thanks again Nicholas for all of your help with these audits.   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 audits Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Jun 3, 2015 at 5:59 PM Hi Nicholas, I will check with the cities and see what I can come up with. Thanks Nicholas. Let us know if you have any more 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, June 3, 2015 1:39 PM Subject: RE: TracFone audits Hi Mike – in regard to the TRS-TracFone WA local cities audits, it appears that there may be overlapping zip codes among each of the cities under audit.   For each of the cities listed in your e-mail below I am hoping that you could specify the zip codes that are exclusive to each of the cities under audit so that we can respond to your data requests.     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 02, 2015 3:59 PM To: Nicholas Ford Subject: TracFone audits   Hi Nicholas,   Good talking with you today.  We doubled checked our records and turns out that the City of Tukwila was also one of the auditing cities.  All of the cities together are:  City of Spokane, City of Renton, City of Burien, City of Federal Way, City of Kennewick and the City of Tukwila.   Let us know if you have any questions.    Thanks again Nicholas for all of your help with the se audits.   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.  Zip Codes Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Tue, Jun 9, 2015 at 12:22 PM Hi Nicholas, Hope everything has been going great for you. Sorry Nicholas, I thought we sent this to you.  Here are the zip codes for five of the six citeies. For Spokane, see attached. This list matches a list we received from Spokane, and the one online at City of Spokane, WA Zip Codes | ZipCode.org         City of Spokane, WA Zip Codes | ZipCode.org Spokane Zip Codes. Washington zip codes and information View on zipcode.org Preview by Yahoo     For Renton, we have 98055, 98056, 98057, 98058, and 98059, and 98178. For Burien, we have 98144, 98146, 98164, 98168. For Federal Way, we have 98003, 98023, 98063, 98093. For Kennewick, we have 99336, 99337 and 99338. We understand that many of these are not completely inside of the cities, but we are hoping that having them will help somewhat in gauging the accuracy of estimates. Be sure to segregate the zip information instead of lumping them all together, because some of the zips are all-in, and some are not. If you happened to collect the suffix of the zip code, for example for Kennewick 99336-0302, those would contain the actuals for the cities. But our guess is that this would only happen sporadically, and would be unreliable information. We are still waiting to hear from Tukwila, and will let you know when we do. Thanks Nicholas. Let us know if you have any questions. 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.  City of Spokane Zip Codes.pdf 63.6kB RE: Zip codes and the audit Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Thu, Jun 11, 2015 at 8:32 AM Hi Mike – thanks for the update.  I’ll be working over the weekend in order to begin rolling out the data early next week, at the latest.  However, please be advised that we believe there could be a number of discrepancies and overlaps regarding the cities’ zip codes, and that we are not in agreement with the zip codes provided.   As an aside, below are the audit periods that I have with respect to each city under audit.  Let me know if you see anything amiss.          Kennewick:  January 1, 2010—November 30, 2014          Burien: January 1, 2003—November 30, 2013          Renton:  January 1, 2007—May 31, 2013          Federal Way:  January 1, 2007—May 31, 2014          Spokane: January 1, 2007—May 31, 2014          Tukwila:  January 1, 2008—November 30, 2013   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, June 10, 2015 6:47 PM To: Nicholas Ford Subject: Zip codes and the audit   Hi Nicholas, Hope all is well with you. We hope to have the zip codes for the City of Tukwila to you soon.  We also received an email from the City of Spokane, and they really would like to see the audit move along a lot more quickly.  They were hoping to have the information requested for the audit by Friday.  They have considered sending out an estimated tax.  Could you give us a time frame of when you could have the information for Spokane?   In addition, let us know if you have any questions or if you need anything else from us for the different cities. 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: Zip codes and the audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Jun 11, 2015 at 6:22 PM Thanks Nicholas for all of your help with these audits.  We really appreciate it.  Also, I am sure we will come up with something that works for both of us concerning the zip codes. Also, see below in your email in bold where there were some corrections on the dates of the audits.  Let us know if you see anything different. Let us know if you have any questions with the information that we need for the audit. 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: Thursday, June 11, 2015 8:31 AM Subject: RE: Zip codes and the audit Hi Mike – thanks for the update.  I’ll be working over the weekend in order to begin rolling out the data early next week, at the latest.  However, please be advised that we believe there could be a number of discrepancies and overlaps regarding the cities’ zip codes, and that we are not in agreement with the zip codes provided.   As an aside, below are the audit periods that I have with respect to each city under audit.  Let me know if you see anything amiss.          Kennewick:  January 1, 2010—November 30, 2014          Burien: January 1, 2003— May 31, 2014          Renton:  January 1, 2007—May 31, 2014          Federal Way:  January 1, 2008—May 31, 2014            Spokane: January 1, 2009 —March 31, 2014          Tukwila:  January 1, 2008—May 31, 2014   Also, could you let us know how you came up with the different dates for Federal Way and Spokane? 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, June 10, 2015 6:47 PM To: Nicholas Ford Subject: Zip codes and the audit   Hi Nicholas, Hope all is well with you. We hope to have the zip codes for the City of Tukwila to you soon.  We also received an email from the City of Spokane, and they really would like to see the audit move along a lot more quickly.  They were hoping to have the information requested for the audit by Friday.  They have considered sending out an estimated tax.  Could you give us a time frame of when you could have the information for Spokane?   In addition, let us know if you have any questions or if you need anything else from us for the different cities. 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. TracFone Renton audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Jun 25, 2015 at 4:17 PM Hi Nicholas, We received an email from the City of Renton and they told us that they have not received the information that was requested for the subpoena. Below is listed the information that was requested for the Renton audit. This information was requested by subpoena on May 5th with forty-five days to comply; these 45 days have passed, and nothing has been received for Renton. Please reply to each of the requests below, stating TracFone's position as to why you have not replied (or possibly how you have already replied or when you plan to reply). For the City of Renton, regarding TracFone Wireless brands including TracFone, NET10 Wireless, Safelink Wireless, Straight Talk, Telcel América, SIMPLE Mobile, and Page Plus Cellular and any other subgroup: A list of all revenue figures by account category earned in Washington State for each year of the audit. A list of all revenue figures by account category earned in Renton, including the March 1, 2008 annexation, for each year of the audit, or a statement saying that TracFone Wireless does not record city-specific data.  Any information regarding how TracFone Wireless breaks out revenues as to what is intrastate and what is interstate, and if these are not broken out, a statement saying that TracFone Wireless does not break out revenues between intrastate and interstate. Invoices for customers in Renton for March of 2008, June of 2010, and September of 2012 and January of 2013. Go ahead and edit out any personal customer information. Renton sales revenues for prepaid cards for each year of the audit; if these figures are not broken out, provide Washington State revenues for prepaid cards for each year of the audit. Revenues for recharge of prepaid cards for each year of the audit; if these figures are not broken out, provide Washington State revenues for recharge of prepaid cards for each year of the audit. Information on how TracFone Wireless sources calls. Information on how TracFone Wireless keeps record of calls and minutes used. 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. Information on whether TracFone Wireless keeps track of the primary residence of the customers (primary place of use). Any other pertinent information relating to this audit Thanks Nicholas. Let us know if you have any questions. 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: Renton zip code data started arriving on June 26, 2015. These emails and attachments have are being submitted separately. Audit question Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Aug 21, 2015 at 1:16 PM Hi Nichols, Hope things have been going well 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 to you? -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 great weekend.. Mike  RE: Audit question Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Mon, Aug 24, 2015 at 10:49 AM Hi Mike – I’ve got a draft answer back from my contacts on your query below.  Expect to have to you shortly once Tax V.P. gets a chance to look over.   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 21, 2015 4:16 PM To: Nicholas Ford Subject: Audit question   Hi Nichols,   Hope things have been going well 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 to you? -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 great weekend..   Mike   Re: Audit question Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Mon, Aug 24, 2015 at 12:05 PM Thanks Nicholas. That sounds great. Have a good afternoon. Mike From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Monday, August 24, 2015 10:46 AM Subject: RE: Audit question Hi Mike – I’ve got a draft answer back from my contacts on your query below.  Expect to have to you shortly once Tax V.P. gets a chance to look over.   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 21, 2015 4:16 PM To: Nicholas Ford Subject: Audit question   Hi Nichols,   Hope things have been going well 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 to you? -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 great weekend..   Mike  RE: Audit question Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Tue, Aug 25, 2015 at 1:37 PM Hi Mike – as discussed, please see responses below (highlighted in bold font) to your audit questions in the attached e-mail.   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? Yes, it is State plus county tax.   Second, what is the Amount column for? Third, how is this amount related to the 911 tax? The amount column in the attached is the total dollar amount of items purchased within the zip code.  It does not include any tax, fees, or assessments.   Third, 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?  See Second question reply, 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, August 21, 2015 4:16 PM To: Nicholas Ford Subject: Audit question   Hi Nichols,   Hope things have been going well 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 to you? -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 great weekend..   Mike  Re: Audit question Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Tue, Aug 25, 2015 at 2:03 PM Thanks Nicholas.  We will review your answers and will get back with you if we have any questions.  Also, how are things coming along with the other cities concerning the WA utility user tax reports? Have a great afternoon. Mike From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Tuesday, August 25, 2015 1:35 PM Subject: RE: Audit question Hi Mike – as discussed, please see responses below (highlighted in bold font) to your audit questions in the attached e-mail.   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? Yes, it is State plus county tax.   Second, what is the Amount column for? Third, how is this amount related to the 911 tax? The amount column in the attached is the total dollar amount of items purchased within the zip code.  It does not include any tax, fees, or assessments.   Third, 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?  See Second question reply, 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, August 21, 2015 4:16 PM To: Nicholas Ford Subject: Audit question   Hi Nichols,   Hope things have been going well 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 to you? -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 great weekend..   Mike Billing Platform Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Sep 25, 2015 at 2:32 PM Hi Nicholas, I hope things have been going well for you. I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross? Thanks, Mike Billing Platform Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Mon, Oct 5, 2015 at 3:00 PM Hi Nicholas, Here is another question that we sent to you. Let us know if you have any questions about it. Thanks Nicholas. Mike ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Friday, September 25, 2015 2:32 PM Subject: Billing Platform Hi Nicholas, I hope things have been going well for you. I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross? Thanks, Mike RE: Billing Platform Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Mon, Oct 5, 2015 at 6:13 PM Hi Mike – we are wrapping up our month-end close.  I’ll be in touch with you tomorrow afternoon regarding your questions.  As an aside, the data related to Federal Way and Kennewick for the audit period has been pulled, and I’ll be looking to get that over to you in short order.   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, October 05, 2015 6:00 PM To: Nicholas Ford Subject: Billing Platform   Hi Nicholas,   Here is another question that we sent to you.   Let us know if you have any questions about it.   Thanks Nicholas.   Mike   ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Friday, September 25, 2015 2:32 PM Subject: Billing Platform   Hi Nicholas,   I hope things have been going well for you.   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Thanks,   Mike   Re: Billing Platform Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Tue, Oct 6, 2015 at 12:44 PM Thanks Nicholas. That sounds great. Have a great afternoon. Mike From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Monday, October 5, 2015 6:11 PM Subject: RE: Billing Platform Hi Mike – we are wrapping up our month-end close.  I’ll be in touch with you tomorrow afternoon regarding your questions.  As an aside, the data related to Federal Way and Kennewick for the audit period has been pulled, and I’ll be looking to get that over to you in short order.   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, October 05, 2015 6:00 PM To: Nicholas Ford Subject: Billing Platform   Hi Nicholas,   Here is another question that we sent to you.   Let us know if you have any questions about it.   Thanks Nicholas.   Mike   ----- Forwarded Message ----- From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Friday, September 25, 2015 2:32 PM Subject: Billing Platform   Hi Nicholas,   I hope things have been going well for you.   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Thanks,   Mike         Billing Platorm Question and Response Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Thu, Oct 15, 2015 at 11:05 AM Hi Mike – below is your question and my answer to the same.   Question:   I have a question concerning the sets of emails you gave me that had to do with your utility taxes. When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross. Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Response:   Each set (of three excel files) contained in my e-mails, Billing Platform, APP, and telephones sales and accessories comprise TracFone’s “gross” direct (retail) sales for a given month when summed together. Therefore, Billing Platform is one of the labels and components that sum up to our gross sales.     Let me know if you have any further question on this.   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. Identifying redempton of airtime geographically Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Oct 15, 2015 at 12:51 PM Hi Nicholas, Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons 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 NOTE: For the Renton audit the above refers to the email Sent: Friday, June 20, 2014 2:58 PM 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).  Re: Billing Platorm Question and Response Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Oct 15, 2015 at 2:53 PM Hey Nicholas, Thanks for your response! So the other brands such as: Page Plus Air, Page Plus, BrightPoint, Straight Talk, SafeLink, Simple Mobile, Telcel America and Net10 Wireless are included in your total gross as well? Are the billing platform, the telephone sales and the accessories that you sent over include all of your brands? If they are not part of the gross, how do you reconcile them? Thanks for your help. Mike From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Thursday, October 15, 2015 11:04 AM Subject: Billing Platorm Question and Response Hi Mike – below is your question and my answer to the same.    Question:   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Response:   Each set (of three excel files) contained in my e-mails, Billing Platform, APP, and telephones sales and accessories comprise TracFone’s “gross” direct (retail) sales for a given month when summed together.  Therefore, Billing Platform is one of the labels and components that sum up to our gross sales.     Let me know if you have any further question on this.   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: Identifying redempton of airtime geographically Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Tue, Nov 3, 2015 at 3:18 PM Hi Nicholas, I also wanted to check and see how thins are coming along with the question below. Let us know if you have any questions. 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: Thursday, October 15, 2015 12:51 PM Subject: Identifying redempton of airtime geographically Hi Nicholas, Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons 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).  NOTE: For the Renton audit the above refers to the email Sent: Friday, June 20, 2014 2:58 PM Fw: Billing Platorm Question and Response Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Tue, Nov 3, 2015 at 3:17 PM Hi Nicholas, Thanks for the information on the City of Tukwila. I also wanted to check and see if you have had a chance to review the question below. 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: Thursday, October 15, 2015 2:53 PM Subject: Re: Billing Platorm Question and Response Hey Nicholas, Thanks for your response! So the other brands such as: Page Plus Air, Page Plus, BrightPoint, Straight Talk, SafeLink, Simple Mobile, Telcel America and Net10 Wireless are included in your total gross as well? Are the billing platform, the telephone sales and the accessories that you sent over include all of your brands? If they are not part of the gross, how do you reconcile them? Thanks for your help. Mike From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Thursday, October 15, 2015 11:04 AM Subject: Billing Platorm Question and Response Hi Mike – below is your question and my answer to the same.    Question:   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Response:   Each set (of three excel files) contained in my e-mails, Billing Platform, APP, and telephones sales and accessories comprise TracFone’s “gross” direct (retail) sales for a given month when summed together.  Therefore, Billing Platform is one of the labels and components that sum up to our gross sales.     Let me know if you have any further question on this.   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.    NOTE: More zip code information started arriving on November 10, 2015. These were submitted separately. Billing Platorm Question and Response Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Mon, Nov 16, 2015 at 3:59 PM Hi Nicholas, Also, wanted to check on how things are coming along with the question I sent you below. 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: Tuesday, November 3, 2015 3:17 PM Subject: Fw: Billing Platorm Question and Response Hi Nicholas, Thanks for the information on the City of Tukwila. I also wanted to check and see if you have had a chance to review the question below. 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: Thursday, October 15, 2015 2:53 PM Subject: Re: Billing Platorm Question and Response Hey Nicholas, Thanks for your response! So the other brands such as: Page Plus Air, Page Plus, BrightPoint, Straight Talk, SafeLink, Simple Mobile, Telcel America and Net10 Wireless are included in your total gross as well? Are the billing platform, the telephone sales and the accessories that you sent over include all of your brands? If they are not part of the gross, how do you reconcile them? Thanks for your help. Mike From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Thursday, October 15, 2015 11:04 AM Subject: Billing Platorm Question and Response Hi Mike – below is your question and my answer to the same.    Question:   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Response:   Each set (of three excel files) contained in my e-mails, Billing Platform, APP, and telephones sales and accessories comprise TracFone’s “gross” direct (retail) sales for a given month when summed together.  Therefore, Billing Platform is one of the labels and components that sum up to our gross sales.     Let me know if you have any further question on this.   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: Billing Platorm Question and Response Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Oct 15, 2015 at 2:53 PM Hey Nicholas, Thanks for your response! So the other brands such as: Page Plus Air, Page Plus, BrightPoint, Straight Talk, SafeLink, Simple Mobile, Telcel America and Net10 Wireless are included in your total gross as well? Are the billing platform, the telephone sales and the accessories that you sent over include all of your brands? If they are not part of the gross, how do you reconcile them? Thanks for your help. Mike From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Thursday, October 15, 2015 11:04 AM Subject: Billing Platorm Question and Response Hi Mike – below is your question and my answer to the same.     Question:   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Response:   Each set (of three excel files) contained in my e-mails, Billing Platform, APP, and telephones sales and accessories comprise TracFone’s “gross” direct (retail) sales for a given month when summed together.  Therefore, Billing Platform is one of the labels and components that sum up to our gross sales.     Let me know if you have any further question on this.   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.     NOTE: For the Renton audit the above refers to the email Sent: Friday, June 20, 2014 2:58 PM d@tracfone.com> To:crisp@trs-integrity.com Wed, Nov 25, 2015 at 7:56 AM Hi Mike – in reference to your questions below, please see the responses inserted in bold font. As an aside, we are working on your remaining question regarding “identifying redemption of airtime geographically.”     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: Thursday, October 15, 2015 5:54 PM To: Nicholas Ford Subject: Re: Billing Platorm Question and Response   Hey Nicholas,   Thanks for your response!    (1)    So the other brands such as: Page Plus Air, Page Plus, BrightPoint, Straight Talk, SafeLink, Simple Mobile, Telcel America and Net10 Wireless are included in your total gross as well? Yes, any purchases relating to those brands would be included in the total gross.     (2)   Are the billing platform, the telephone sales and the accessories that you sent over include all of your brands? Yes, they do include all brands.     (3)   If they are not part of the gross, how do you reconcile them?  See responses above.   Thanks for your help.   Mike     From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Thursday, October 15, 2015 11:04 AM Subject: Billing Platorm Question and Response   Hi Mike – below is your question and my answer to the same.     Question:   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Response:   Each set (of three excel files) contained in my e-mails, Billing Platform, APP, and telephones sales and accessories comprise TracFone’s “gross” direct (retail) sales for a given month when summed together.  Therefore, Billing Platform is one of the labels and components that sum up to our gross sales.     Let me know if you have any further question on this.   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: Billing Platorm Question and Response Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Nov 25, 2015 at 2:05 PM Hi Nicholas, Thanks for your reply to my question.  After reviewing your email, we will still need to see a month reconciled showing that each brand amount that was sold in that city adds up to the amount that you sent to us.  For Tukwila, could you send us the month of January of 2011, for Burien , could you send us the month of March of 2012, for Spokane, could you send us the month of December 2013, for Kennewick, could you send us the month of June of 2014 and for Federal Way, could you send us the month of November of 2014. Also, because we will not be able to complete the audit by the end of the month, we will need any waiver forms signed for any city that needs one.  I plan to send you what is needed by early next week.  Waiver forms need to be signed as soon as possible to avoid an estimated tax situation since we are at the end of the year. Let us know if you have any questions with the information above or with the other question that we sent you on November 16, 2015 concerning your ability to identify airtime redemption geographically by zip.  Thanks Nicholas. Have a Happy Thanksgiving. 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, November 25, 2015 7:56 AM Subject: RE: Billing Platorm Question and Response Hi Mike – in reference to your questions below, please see the responses inserted in bold font.   As an aside, we are working on your remaining question regarding “identifying redemption of airtime geographically.”     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: Thursday, October 15, 2015 5:54 PM To: Nicholas Ford Subject: Re: Billing Platorm Question and Response   Hey Nicholas,   Thanks for your response!   (1)    So the other brands such as: Page Plus Air, Page Plus, BrightPoint, Straight Talk, SafeLink, Simple Mobile, Telcel America and Net10 Wireless are included in your total gross as well? Yes, any purchases relating to those brands would be included in the total gross.    (2)   Are the billing platform, the telephone sales and the accessories that you sent over include all of your brands? Yes, they do include all brands.    (3)   If they are not part of the gross, how do you reconcile them?  See responses above.   Thanks for your help.   Mike     From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Thursday, October 15, 2015 11:04 AM Subject: Billing Platorm Question and Response   Hi Mike – below is your question and my answer to the same.    Question:   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Response:   Each set (of three excel files) contained in my e-mails, Billing Platform, APP, and telephones sales and accessories comprise TracFone’s “gross” direct (retail) sales for a given month when summed together.  Therefore, Billing Platform is one of the labels and components that sum up to our gross sales.     Let me know if you have any further question on this.   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: Billing Platorm Question and Response Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Dec 3, 2015 at 3:11 PM Hi Nicholas, Hope all is well with you. I wanted to check and see how things are coming along with the items below. Let me know if you have any questions. Thanks Nicholas. Have a great eveining. 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, November 25, 2015 2:05 PM Subject: Re: Billing Platorm Question and Response Hi Nicholas, Thanks for your reply to my question.  After reviewing your email, we will still need to see a month reconciled showing that each brand amount that was sold in that city adds up to the amount that you sent to us.  For Tukwila, could you send us the month of January of 2011, for Burien , could you send us the month of March of 2012, for Spokane, could you send us the month of December 2013, for Kennewick, could you send us the month of June of 2014 and for Federal Way, could you send us the month of November of 2014. Also, because we will not be able to complete the audit by the end of the month, we will need any waiver forms signed for any city that needs one.  I plan to send you what is needed by early next week.  Waiver forms need to be signed as soon as possible to avoid an estimated tax situation since we are at the end of the year. Let us know if you have any questions with the information above or with the other question that we sent you on November 16, 2015 concerning your ability to identify airtime redemption geographically by zip.  Thanks Nicholas. Have a Happy Thanksgiving. 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, November 25, 2015 7:56 AM Subject: RE: Billing Platorm Question and Response Hi Mike – in reference to your questions below, please see the responses inserted in bold font.   As an aside, we are working on your remaining question regarding “identifying redemption of airtime geographically.”     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: Thursday, October 15, 2015 5:54 PM To: Nicholas Ford Subject: Re: Billing Platorm Question and Response   Hey Nicholas,   Thanks for your response!   (1)    So the other brands such as: Page Plus Air, Page Plus, BrightPoint, Straight Talk, SafeLink, Simple Mobile, Telcel America and Net10 Wireless are included in your total gross as well? Yes, any purchases relating to those brands would be included in the total gross.    (2)   Are the billing platform, the telephone sales and the accessories that you sent over include all of your brands? Yes, they do include all brands.    (3)   If they are not part of the gross, how do you reconcile them?  See responses above.   Thanks for your help.   Mike     From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Thursday, October 15, 2015 11:04 AM Subject: Billing Platorm Question and Response   Hi Mike – below is your question and my answer to the same.    Question:   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Response:   Each set (of three excel files) contained in my e-mails, Billing Platform, APP, and telephones sales and accessories comprise TracFone’s “gross” direct (retail) sales for a given month when summed together.  Therefore, Billing Platform is one of the labels and components that sum up to our gross sales.     Let me know if you have any further question on this.   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: Billing Platorm Question and Response Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Dec 3, 2015 at 3:49 PM Hi Nicholas, I also forgot to ask you to send a reconciliation for the City of Renton.  Could you send us a reconciliation for the month June of 2015 showing how all the brands are reconciled to the amount that was sent to us by you. 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: Thursday, December 3, 2015 3:11 PM Subject: Fw: Billing Platorm Question and Response Hi Nicholas, Hope all is well with you. I wanted to check and see how things are coming along with the items below. Let me know if you have any questions. Thanks Nicholas. Have a great eveining. 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, November 25, 2015 2:05 PM Subject: Re: Billing Platorm Question and Response Hi Nicholas, Thanks for your reply to my question.  After reviewing your email, we will still need to see a month reconciled showing that each brand amount that was sold in that city adds up to the amount that you sent to us.  For Tukwila, could you send us the month of January of 2011, for Burien , could you send us the month of March of 2012, for Spokane, could you send us the month of December 2013, for Kennewick, could you send us the month of June of 2014 and for Federal Way, could you send us the month of November of 2014. Also, because we will not be able to complete the audit by the end of the month, we will need any waiver forms signed for any city that needs one.  I plan to send you what is needed by early next week.  Waiver forms need to be signed as soon as possible to avoid an estimated tax situation since we are at the end of the year. Let us know if you have any questions with the information above or with the other question that we sent you on November 16, 2015 concerning your ability to identify airtime redemption geographically by zip.  Thanks Nicholas. Have a Happy Thanksgiving. 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, November 25, 2015 7:56 AM Subject: RE: Billing Platorm Question and Response Hi Mike – in reference to your questions below, please see the responses inserted in bold font.   As an aside, we are working on your remaining question regarding “identifying redemption of airtime geographically.”     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: Thursday, October 15, 2015 5:54 PM To: Nicholas Ford Subject: Re: Billing Platorm Question and Response   Hey Nicholas,   Thanks for your response!   (1)    So the other brands such as: Page Plus Air, Page Plus, BrightPoint, Straight Talk, SafeLink, Simple Mobile, Telcel America and Net10 Wireless are included in your total gross as well? Yes, any purchases relating to those brands would be included in the total gross.    (2)   Are the billing platform, the telephone sales and the accessories that you sent over include all of your brands? Yes, they do include all brands.    (3)   If they are not part of the gross, how do you reconcile them?  See responses above.   Thanks for your help.   Mike     From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Thursday, October 15, 2015 11:04 AM Subject: Billing Platorm Question and Response   Hi Mike – below is your question and my answer to the same.    Question:   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Response:   Each set (of three excel files) contained in my e-mails, Billing Platform, APP, and telephones sales and accessories comprise TracFone’s “gross” direct (retail) sales for a given month when summed together.  Therefore, Billing Platform is one of the labels and components that sum up to our gross sales.     Let me know if you have any further question on this.   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.      Billing Platorm Question and Response Sent TRS <crisp@trs-integrity.com> To:nford@tracfone.com Mon, Dec 7, 2015 at 3:44 PM Hi Nicholas, Hope you had a great weekend. I also wanted to check and see how things are coming along with the information that we requested below.   Let us know if you have any questions. 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: Wednesday, November 25, 2015 2:05 PM Subject: Re: Billing Platorm Question and Response Hi Nicholas, Thanks for your reply to my question.  After reviewing your email, we will still need to see a month reconciled showing that each brand amount that was sold in that city adds up to the amount that you sent to us.  For Tukwila, could you send us the month of January of 2011, for Burien , could you send us the month of March of 2012, for Spokane, could you send us the month of December 2013, for Kennewick, could you send us the month of June of 2014 and for Federal Way, could you send us the month of November of 2014. Also, because we will not be able to complete the audit by the end of the month, we will need any waiver forms signed for any city that needs one.  I plan to send you what is needed by early next week.  Waiver forms need to be signed as soon as possible to avoid an estimated tax situation since we are at the end of the year. Let us know if you have any questions with the information above or with the other question that we sent you on November 16, 2015 concerning your ability to identify airtime redemption geographically by zip.  Thanks Nicholas. Have a Happy Thanksgiving. 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, November 25, 2015 7:56 AM Subject: RE: Billing Platorm Question and Response Hi Mike – in reference to your questions below, please see the responses inserted in  bold font.   As an aside, we are working on your remaining question regarding “identifying redemption of airtime geographically.”     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: Thursday, October 15, 2015 5:54 PM To: Nicholas Ford Subject: Re: Billing Platorm Question and Response   Hey Nicholas,   Thanks for your response!    (1)    So the other brands such as: Page Plus Air, Page Plus, BrightPoint, Straight Talk, SafeLink, Simple Mobile, Telcel America and Net10 Wireless are included in your total gross as well? Yes, any purchases relating to those brands would be included in the total gross.     (2)   Are the billing platform, the telephone sales and the accessories that you sent over include all of your brands? Yes, they do include all brands.     (3)   If they are not part of the gross, how do you reconcile them?  See responses above.   Thanks for your help.   Mike     From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com>  Sent: Thursday, October 15, 2015 11:04 AM Subject: Billing Platorm Question and Response   Hi Mike – below is your question and my answer to the same.     Question:   I have a question concerning the sets of emails you gave me that had to do with your utility taxes.  When looking through the attachments, I saw the billing platform, but I was not sure if that was your gross sales or simply one of many labels that all summed up to your gross.  Can you tell me if you have any other labels or if the billing platform in your emails represent your gross?   Response:   Each set (of three excel files) contained in my e-mails, Billing Platform, APP, and telephones sales and accessories comprise TracFone’s “gross” direct (retail) sales for a given month when summed together.  Therefore, Billing Platform is one of the labels and components that sum up to our gross sales.     Let me know if you have any further question on this.   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: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Fri, Dec 11, 2015 at 10:02 AM Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail.   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service.   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, November 16, 2015 7:00 PM To: Nicholas Ford Subject: Identifying redempton of airtime geographically   Hi Nichols, Hope you had a great weekend. I also wanted to check and see how things are coming along with the questions we sent you below. 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: Tuesday, November 3, 2015 3:18 PM Subject: Fw: Identifying redempton of airtime geographically   Hi Nicholas, I also wanted to check and see how thins are coming along with the question below. Let us know if you have any questions. 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: Thursday, October 15, 2015 12:51 PM Subject: Identifying redempton of airtime geographically   Hi Nicholas, Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons 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).      20151211 - TracFone-Kennewick Audit - SOL Waiver.pdf 199.2kB  Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Dec 11, 2015 at 3:04 PM Hi Nicholas, Thank for the email.  We will review it and get back with you. 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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail.   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service.   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, November 16, 2015 7:00 PM To: Nicholas Ford Subject: Identifying redempton of airtime geographically   Hi Nichols, Hope you had a great weekend. I also wanted to check and see how things are coming along with the questions we sent you below. 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: Tuesday, November 3, 2015 3:18 PM Subject: Fw: Identifying redempton of airtime geographically   Hi Nicholas, I also wanted to check and see how thins are coming along with the question below. Let us know if you have any questions. 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: Thursday, October 15, 2015 12:51 PM Subject: Identifying redempton of airtime geographically   Hi Nicholas, Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons 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).     Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Sent TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Dec 31, 2015 at 12:12 PM Hi Nicholas, Hope things have been going well with you. We hope to get back with you next week concerning the email below.   I also wanted to check and see how things are coming along with the reconciliations (email sent to you on November 26th) for the different brands to the gross revenues that you sent us. Let us know if you have any questions. Thanks Nicholas. Have a Happy New Year! 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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail.   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service.   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, November 16, 2015 7:00 PM To: Nicholas Ford Subject: Identifying redempton of airtime geographically   Hi Nichols, Hope you had a great weekend. I also wanted to check and see how things are coming along with the questions we sent you below. 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: Tuesday, November 3, 2015 3:18 PM Subject: Fw: Identifying redempton of airtime geographically   Hi Nicholas, I also wanted to check and see how thins are coming along with the question below. Let us know if you have any questions. 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: Thursday, October 15, 2015 12:51 PM Subject: Identifying redempton of airtime geographically   Hi Nicholas, Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons 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).     Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Inbox  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Jan 8, 2016 at 2:26 PM Hi Nicolas, Hope things have been going well with you. We have replied to your comments below in bold lettering.   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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail .   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service. After reviewing your email we would have to disagree with your interpretation of the RCW quoted above; it is our understanding that this part of the RCW instead protects the company that sells the airtime to TracFone when it states: " . . . the city shall not impose the fee or tax on that portion of network telephone service which represents . . . charges for network telephone service that is purchased for the purpose of resale . . . " It is they that "charged" TracFone for the "service purchased for resale."  Walmart is not selling telephone service. Walmart is not a utility provider. In the fact that TracFone sold the cards to Walmart, the State of Washington still sees TracFone as the seller of the utility to the customer, as the customers purchase a card from Walmart, but the customers are only buying the means of accessing the utility you are providing for them; the cards reference you, and your company is the company that connects them to the utility service. It is the utility service usage that you, and not Walmart, provide to the customer that is taxable by the City.  All the utilities providing services through cards sold at Walmart must pay the utility taxes themselves. Another important point to note is that it is not sales that are taxed, but rather usage. But since TracFone does not keep track of airtime, the utility usage must be estimated, most likely using sales data.  We need to know, then, if the data you are sending regarding billing sales includes the sales done by Walmart and other retailers.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service. We agree that interstate and internet are generally not taxable. However, in the case of interstate long distance, Washington State law  RCW 82.32.510 requires that the interstate portion be broken out in the regular course of business"; if not, the aggregate amount may be taxed. If TracFone does not do this, it is possible that your company will owe taxes on the whole of long distance charges.  Would you be able to break out the interstate amounts?  Regarding internet, since the data you sent us breaks out internet, these amounts will be easy to identify and would not be taxable.  Let us know if you have any questions Thanks Nicholas. Have a great afternoon.   Mike 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, November 16, 2015 7:00 PM To: Nicholas Ford Subject: Identifying redempton of airtime geographically   Hi Nichols, Hope you had a great weekend. I also wanted to check and see how things are coming along with the questions we sent you below. 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: Tuesday, November 3, 2015 3:18 PM Subject: Fw: Identifying redempton of airtime geographically   Hi Nicholas, I also wanted to check and see how thins are coming along with the question below. Let us know if you have any questions. 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: Thursday, October 15, 2015 12:51 PM Subject: Identifying redempton of airtime geographically   Hi Nicholas, Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons 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).     NOTE: There was a repeat of the above sent at 2:58pm. Same email. Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Jan 29, 2016 at 1:45 PM Hi Nicholas, Hope everything is going well with you. Also, just checking to see if you have had a chance to review the email below. Have a great weekend. 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.  From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Friday, January 8, 2016 2:58 PM Subject: Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Nicolas, Hope things have been going well with you. We have replied to your comments below in bold lettering.   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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail.   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service. After reviewing your email we would have to disagree with your interpretation of the RCW quoted above; it is our understanding that this part of the RCW instead protects the company that sells the airtime to TracFone when it states: " . . . the city shall not impose the fee or tax on that portion of network telephone service which represents . . . charges for network telephone service that is purchased for the purpose of resale . . . " It is they that "charged" TracFone for the "service purchased for resale."  Walmart is not selling telephone service. Walmart is not a utility provider. In the fact that TracFone sold the cards to Walmart, the State of Washington still sees TracFone as the seller of the utility to the customer, as the customers purchase a card from Walmart, but the customers are only buying the means of accessing the utility you are providing for them; the cards reference you, and your company is the company that connects them to the utility service. It is the utility service  usage that you, and not Walmart, provide to the customer that is taxable by the City.  All the utilities providing services through cards sold at Walmart must pay the utility taxes themselves. Another important point to note is that it is not sales that are taxed, but rather usage. But since TracFone does not keep track of airtime, the utility usage must be estimated, most likely using sales data.  We need to know, then, if the data you are sending regarding billing sales includes the sales done by Walmart and other retailers.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service. We agree that interstate and internet are generally not taxable. However, in the case of interstate long distance, Washington State law  RCW 82.32.510 requires that the interstate portion be broken out in the regular course of business"; if not, the aggregate amount may be taxed. If TracFone does not do this, it is possible that your company will owe taxes on the whole of long distance charges.  Would you be able to break out the interstate amounts?  Regarding internet, since the data you sent us breaks out internet, these amounts will be easy to identify and would not be taxable.  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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail .   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service.   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, November 16, 2015 7:00 PM To: Nicholas Ford Subject: Identifying redempton of airtime geographically   Hi Nichols, Hope you had a great weekend. I also wanted to check and see how things are coming along with the questions we sent you below. 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: Tuesday, November 3, 2015 3:18 PM Subject: Fw: Identifying redempton of airtime geographically   Hi Nicholas, I also wanted to check and see how thins are coming along with the question below. Let us know if you have any questions. 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: Thursday, October 15, 2015 12:51 PM Subject: Identifying redempton of airtime geographically   Hi Nicholas, Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons 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).     Fw: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Feb 3, 2016 at 2:25 PM Hi Nicholas, Just checking to see if you have had a chance to review the email below. Have a great afternoon. 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.  From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Friday, January 8, 2016 2:58 PM Subject: Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Nicolas, Hope things have been going well with you. We have replied to your comments below in bold lettering.   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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail .   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service. After reviewing your email we would have to disagree with your interpretation of the RCW quoted above; it is our understanding that this part of the RCW instead protects the company that sells the airtime to TracFone when it states: " . . . the city shall not impose the fee or tax on that portion of network telephone service which represents . . . charges for network telephone service that is purchased for the purpose of resale . . . " It is they that "charged" TracFone for the "service purchased for resale."  Walmart is not selling telephone service. Walmart is not a utility provider. In the fact that TracFone sold the cards to Walmart, the State of Washington still sees TracFone as the seller of the utility to the customer, as the customers purchase a card from Walmart, but the customers are only buying the means of accessing the utility you are providing for them; the cards reference you, and your company is the company that connects them to the utility service. It is the utility service  usage that you, and not Walmart, provide to the customer that is taxable by the City.  All the utilities providing services through cards sold at Walmart must pay the utility taxes themselves. Another important point to note is that it is not sales that are taxed, but rather usage. But since TracFone does not keep track of airtime, the utility usage must be estimated, most likely using sales data.  We need to know, then, if the data you are sending regarding billing sales includes the sales done by Walmart and other retailers.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service. We agree that interstate and internet are generally not taxable. However, in the case of interstate long distance, Washington State law  RCW 82.32.510 requires that the interstate portion be broken out in the regular course of business"; if not, the aggregate amount may be taxed. If TracFone does not do this, it is possible that your company will owe taxes on the whole of long distance charges.  Would you be able to break out the interstate amounts?  Regarding internet, since the data you sent us breaks out internet, these amounts will be easy to identify and would not be taxable.  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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail .   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service.   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, November 16, 2015 7:00 PM To: Nicholas Ford Subject: Identifying redempton of airtime geographically   Hi Nichols, Hope you had a great weekend. I also wanted to check and see how things are coming along with the questions we sent you below. 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: Tuesday, November 3, 2015 3:18 PM Subject: Fw: Identifying redempton of airtime geographically   Hi Nicholas, I also wanted to check and see how thins are coming along with the question below. Let us know if you have any questions. 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: Thursday, October 15, 2015 12:51 PM Subject: Identifying redempton of airtime geographically   Hi Nicholas, Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons 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).     RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Wed, Feb 3, 2016 at 3:51 PM Hi Mike – we’ve just completed our review of your email and we would like to set up a meeting with you to discuss further.   As you may recall, you had sent me the email below on 12/18/14 in response to our request to meet with you on 1/20/15 to go over our thoughts concerning a potential way forward with regard to your audit s.   12/18/14 e-mail from you – “After further review of the situation, TRS will need sufficient time to meet with the various cities to discuss the audit.  In addition, we will also be seeking legal counsel on how to best move forward with the audit.  At this time, we will not be able to meet with Mr. Dillon and Mr. Edwards.  After we have concluded our meetings, we will contact you.  At this time, we do not have a time table, but we hope to move as fast as we can on this audit.”    Essentially, I am asking that we revisit your timetable on the issue of our meeting request.  Kindly let me know your thoughts in that regard.   respectfully,   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, February 03, 2016 5:25 PM To: Nicholas Ford Subject: Fw: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Nicholas,   Just checking to see if you have had a chance to review the email below.   Have a great afternoon.   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.      From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Friday, January 8, 2016 2:58 PM Subject: Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Nicolas,   Hope things have been going well with you.   We have replied to your comments below in bold lettering.   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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail .   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service. After reviewing your email we would have to disagree with your interpretation of the RCW quoted above; it is our understanding that this part of the RCW instead protects the company that sells the airtime to TracFone when it states: " . . . the city shall not impose the fee or tax on that portion of network telephone service which represents . . . charges for network telephone service that is purchased for the purpose of resale . . . " It is they that "charged" TracFone for the "service purchased for resale."  Walmart is not selling telephone service. Walmart is not a utility provider. In the fact that TracFone sold the cards to Walmart, the State of Washington still sees TracFone as the seller of the utility to the customer, as the customers purchase a card from Walmart, but the customers are only buying the means of accessing the utility you are providing for them; the cards reference you, and your company is the company that connects them to the utility service. It is the utility service usage that you, and not Walmart, provide to the customer that is taxable by the City.  All the utilities providing services through cards sold at Walmart must pay the utility taxes themselves. Another important point to note is that it is not sales that are taxed, but rather usage. But since TracFone does not keep track of airtime, the utility usage must be estimated, most likely using sales data.  We need to know, then, if the data you are sending regarding billing sales includes the sales done by Walmart and other retailers.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service. We agree that interstate and internet are generally not taxable. However, in the case of interstate long distance, Washington State law RCW 82.32.510 requires that the interstate portion be broken out in the regular course of business"; if not, the aggregate amount may be taxed. If TracFone does not do this, it is possible that your company will owe taxes on the whole of long distance charges.  Would you be able to break out the interstate amounts?    Regarding internet, since the data you sent us breaks out internet, these amounts will be easy to identify and would not be taxable.  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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail .   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service.   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, November 16, 2015 7:00 PM To: Nicholas Ford Subject: Identifying redempton of airtime geographically   Hi Nichols,   Hope you had a great weekend.   I also wanted to check and see how things are coming along with the questions we sent you below.   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: Tuesday, November 3, 2015 3:18 PM Subject: Fw: Identifying redempton of airtime geographically   Hi Nicholas,   I also wanted to check and see how thins are coming along with the question below.   Let us know if you have any questions.   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: Thursday, October 15, 2015 12:51 PM Subject: Identifying redempton of airtime geographically   Hi Nicholas,   Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons   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).         Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Feb 5, 2016 at 1:59 PM Hi Nicholas, Thanks for the email.  In the email that we sent to you on December 18, 2014, we mentioned that we needed to discuss with each of the cities how to move forward with the audit.   After we reviewed the situation with them, the cities determined that we would need the financial information that we requested for the audit before we would be able to have a meeting, if necessary, between their attorneys and your attorneys.  At this point, we do not have the information that we need to move forward with the audit.  Once we have completed the audit, then at that point we would be able to discuss any questions and deal with any issues that you may have with the audit. The information that we have requested first dealt with the monthly revenue figures that you sent to us for each month for each city.  We then asked you if the revenue figures also included all of the different brands, and you sent us an email stating that they do include all of the brands.   Currently, we are still needing the following information in order to proceed with the audit: We need you to reconcile the amounts for each brand for the month we specified for each city.   We need to know if the data you are sending regarding billing sales includes the sales done by Walmart and other retailers. We need to know if you would be able to break out the interstate amounts for the long-distance charges. We understand that TracFone may object to our conclusions as to the taxability of certain items, or even of the whole. But the ordinances require that companies open their books to auditors so that audits can be conducted according to the understanding of the city and its auditors. Once the audit is completed, that is the time during which the taxpayer has the right to object to the findings, rather than before the audit is completed. There will be time for such discussions once all of the issues are clearly delineated by the audit findings. Nicholas, we do very much appreciate the assistance you provide in helping us bring this audit to completion. 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.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Wednesday, February 3, 2016 3:51 PM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Mike – we’ve just completed our review of your email and we would like to set up a meeting with you to discuss further.   As you may recall, you had sent me the email below on 12/18/14 in response to our request to meet with you on 1/20/15 to go over our thoughts concerning a potential way forward with regard to your audit s.   12/18/14 e-mail from you – “After further review of the situation, TRS will need sufficient time to meet with the various cities to discuss the audit.  In addition, we will also be seeking legal counsel on how to best move forward with the audit.  At this time, we will not be able to meet with Mr. Dillon and Mr. Edwards.  After we have concluded our meetings, we will contact you.  At this time, we do not have a time table, but we hope to move as fast as we can on this audit.”    Essentially, I am asking that we revisit your timetable on the issue of our meeting request.  Kindly let me know your thoughts in that regard.   respectfully,   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, February 03, 2016 5:25 PM To: Nicholas Ford Subject: Fw: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Nicholas,   Just checking to see if you have had a chance to review the email below.   Have a great afternoon.   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.      From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Friday, January 8, 2016 2:58 PM Subject: Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Nicolas,   Hope things have been going well with you.   We have replied to your comments below in bold lettering.   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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail .   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service. After reviewing your email we would have to disagree with your interpretation of the RCW quoted above; it is our understanding that this part of the RCW instead protects the company that sells the airtime to TracFone when it states: " . . . the city shall not impose the fee or tax on that portion of network telephone service which represents . . . charges for network telephone service that is purchased for the purpose of resale . . . " It is they that "charged" TracFone for the "service purchased for resale."  Walmart is not selling telephone service. Walmart is not a utility provider. In the fact that TracFone sold the cards to Walmart, the State of Washington still sees TracFone as the seller of the utility to the customer, as the customers purchase a card from Walmart, but the customers are only buying the means of accessing the utility you are providing for them; the cards reference you, and your company is the company that connects them to the utility service. It is the utility service usage that you, and not Walmart, provide to the customer that is taxable by the City.  All the utilities providing services through cards sold at Walmart must pay the utility taxes themselves. Another important point to note is that it is not sales that are taxed, but rather usage. But since TracFone does not keep track of airtime, the utility usage must be estimated, most likely using sales data.  We need to know, then, if the data you are sending regarding billing sales includes the sales done by Walmart and other retailers.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service. We agree that interstate and internet are generally not taxable. However, in the case of interstate long distance, Washington State law RCW 82.32.510 requires that the interstate portion be broken out in the regular course of business"; if not, the aggregate amount may be taxed. If TracFone does not do this, it is possible that your company will owe taxes on the whole of long distance charges.  Would you be able to break out the interstate amounts?    Regarding internet, since the data you sent us breaks out internet, these amounts will be easy to identify and would not be taxable.  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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail .   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service.   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, November 16, 2015 7:00 PM To: Nicholas Ford Subject: Identifying redempton of airtime geographically   Hi Nichols,   Hope you had a great weekend.   I also wanted to check and see how things are coming along with the questions we sent you below.   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: Tuesday, November 3, 2015 3:18 PM Subject: Fw: Identifying redempton of airtime geographically   Hi Nicholas,   I also wanted to check and see how thins are coming along with the question below.   Let us know if you have any questions.   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: Thursday, October 15, 2015 12:51 PM Subject: Identifying redempton of airtime geographically   Hi Nicholas,   Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons   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   acFone 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). 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.          Tr                 TracFone does not utilize primary place of use (PPU).         Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Feb 19, 2016 at 1:39 PM Hi Nicholas, Hope all is going well. I also wanted to check and see how things are coming along with the information that we need for the audit.  I know the cities are concern about moving forward with the audits.  Let us know if you have any questions concerning the information that we need.  This included the reconciling of the information that you sent to us for one month for each city and for the other information listed 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.  From: Nicholas Ford <nford@tracfone.com> To: TRS <crisp@trs-integrity.com> Sent: Wednesday, February 3, 2016 3:51 PM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED Hi Mike – we’ve just completed our review of your email and we would like to set up a meeting with you to discuss further.   As you may recall, you had sent me the email below on 12/18/14 in response to our request to meet with you on 1/20/15 to go over our thoughts concerning a potential way forward with regard to your audit s.   12/18/14 e-mail from you – “After further review of the situation, TRS will need sufficient time to meet with the various cities to discuss the audit.  In addition, we will also be seeking legal counsel on how to best move forward with the audit.  At this time, we will not be able to meet with Mr. Dillon and Mr. Edwards.  After we have concluded our meetings, we will contact you.  At this time, we do not have a time table, but we hope to move as fast as we can on this audit.”    Essentially, I am asking that we revisit your timetable on the issue of our meeting request.  Kindly let me know your thoughts in that regard.   respectfully,   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, February 03, 2016 5:25 PM To: Nicholas Ford Subject: Fw: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Nicholas,   Just checking to see if you have had a chance to review the email below.   Have a great afternoon.   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.      From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Friday, January 8, 2016 2:58 PM Subject: Re: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Nicolas,   Hope things have been going well with you.   We have replied to your comments below in bold lettering.   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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail .   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service. After reviewing your email we would have to disagree with your interpretation of the RCW quoted above; it is our understanding that this part of the RCW instead protects the company that sells the airtime to TracFone when it states: " . . . the city shall not impose the fee or tax on that portion of network telephone service which represents . . . charges for network telephone service that is purchased for the purpose of resale . . . " It is they that "charged" TracFone for the "service purchased for resale."  Walmart is not selling telephone service. Walmart is not a utility provider. In the fact that TracFone sold the cards to Walmart, the State of Washington still sees TracFone as the seller of the utility to the customer, as the customers purchase a card from Walmart, but the customers are only buying the means of accessing the utility you are providing for them; the cards reference you, and your company is the company that connects them to the utility service. It is the utility service usage that you, and not Walmart, provide to the customer that is taxable by the City.  All the utilities providing services through cards sold at Walmart must pay the utility taxes themselves. Another important point to note is that it is not sales that are taxed, but rather usage. But since TracFone does not keep track of airtime, the utility usage must be estimated, most likely using sales data.  We need to know, then, if the data you are sending regarding billing sales includes the sales done by Walmart and other retailers.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service. We agree that interstate and internet are generally not taxable. However, in the case of interstate long distance, Washington State law RCW 82.32.510 requires that the interstate portion be broken out in the regular course of business"; if not, the aggregate amount may be taxed. If TracFone does not do this, it is possible that your company will owe taxes on the whole of long distance charges.  Would you be able to break out the interstate amounts?    Regarding internet, since the data you sent us breaks out internet, these amounts will be easy to identify and would not be taxable.  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, December 11, 2015 9:59 AM Subject: RE: Identifying redemption of airtime geographically & Kennewick SOL Waiver ATTACHED   Hi Mike – as discussed, please see our response to your question – relating to identifying redemption of airtime geographically – below.  The signed SOL waiver for Kennewick is also attached to this e-mail .   TracFone is a non-facilities based reseller of prepaid wireless airtime.  Much of the company’s revenue is from wholesale sales of prepaid wireless airtime cards, and is not subject to local utility tax.  RCW 35.21.714(1) (excluding the sale of telephone service “for resale” from local utility tax).    While TracFone can track redemptions of airtime purchased by consumers from TracFone’s wholesale customers (i.e. Walmart and other retailers) according to the zip code provided by the end user when a handset is activated, those reports do not track either calls or service (airtime) usage, such information is not relevant to local utility taxes, which are imposed on gross revenue from intrastate toll telephone service.   TracFone also makes direct retail sales of prepaid airtime to consumers.  TracFone can track its direct sales of airtime by customer’s credit card billing address.  However, only a portion of TracFone’s direct sales are subject to local utility tax in the consumer’s city.  Local utility tax only applies to gross revenue from retail customers of intrastate toll telephone service; it does not apply to revenue from interstate telephone service, RCW 35.21.714(1), or to internet service. Community Telecable v. Seattle, 164 Wn.2d 35 (2008). Customers use prepaid wireless airtime not just (or even primarily) for taxable intrastate telephone service, but also for nontaxable interstate and internet service.  Consequently, revenue from sales to consumers with a zip code in the cities you are auditing for will need to be adjusted to deduct the portion of revenue from interstate telephone service and internet service.   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, November 16, 2015 7:00 PM To: Nicholas Ford Subject: Identifying redempton of airtime geographically   Hi Nichols,   Hope you had a great weekend.   I also wanted to check and see how things are coming along with the questions we sent you below.   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: Tuesday, November 3, 2015 3:18 PM Subject: Fw: Identifying redempton of airtime geographically   Hi Nicholas,   I also wanted to check and see how thins are coming along with the question below.   Let us know if you have any questions.   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: Thursday, October 15, 2015 12:51 PM Subject: Identifying redempton of airtime geographically   Hi Nicholas,   Below is the other question that we sent to you.  Thanks for sending the email for the billing platform.  We will let you know if we have any more quesitons   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).         TracFone-City of Renton, Washington Telephone Utility Tax Audit -- Attachments: June 2015 Sample Period Reconciliation -- Customer Transaction-Level D Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Wed, Mar 2, 2016 at 12:17 PM Hi Mike -- in connection with the City of Renton, Washington Telephone Utility Tax Audit, please find attached the customer transaction-level detail files for the June 2015 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  20160302 - TracFone-Renton WA Audit June 2015 APPT Transaction Detail.XLSB 25.7kB 20160302 - TracFone-Renton WA Audit June 2015 BP Transaction Detail.XLSB 25.9kB 20160302 - TracFone-Renton WA Audit June 2015 Phones Transaction Detail.xlsx 17.2kB  Initial questions on information sent to TRS Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Tue, Mar 29, 2016 at 1:40 PM Hi Nicholas, Hope things are going well with you. I have been reviewing the information that you sent to us, and I have some initial questions that I would like to ask you: APPT Transactions Detail Report: What does these mean:  "Redacted - No subpoena was received,"  "Billed Amt." and "X Amt." What is the difference between the X Amt. and the Billed Amt.? What is the tax amount and how did you calculate it? Billing Platform Transaction Detail Report: What is: OTAPURCH, Enrollment, Recurring, BN Enrollment What is the tax amount and how did you calculate it? Telephone Accessories Custom Transaction - Level Detail : We are assuming this is equipment and/or accessories sold to customers.  On the reports that you sent to us, we also noticed these apparent discrepancies: In the information that was sent for the City of Tukwila, the amounts under Billing Platform Transaction Detail Report that you sent to us on 11/3/15 do not match up with the amounts that were sent to us on 3/7/16.  Also, there is an amount that is reported under the X amount for the email that you sent to us on 3/7/16 for the Billing Platform Transaction Detail Report, but there is no amount that is reported on the email that you sent to us on 11/3/15.  We will need to know why. In the City of Burien, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 11/30/15 and 2/25/16. This is also the case on the Billing Platform Customer Transaction Level Detail Report.  Also, there is an amount that is reported under the X amount for the Billing Platform Detail Report for the email that you sent to us on 2/25/16, but there is no amount that is reported on the email that you sent to us on 11/30/15.  We will need to know why. In the City of Kennewick, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 10/09/15 and 2/29/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Billing amount for 2/29/16, but there was a zero amount reported on the email that you sent to us on 10/09/15.   We also notice that you have a brand called Page Plus.  Are there sales happening for each brand in each city? If not, we will need to know why not. In the City of Spokane, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 7/02/15 and 3/4/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Tax amount for 3/4/16, but there was a zero amount reported on the email that you sent to us on 7/02/15.  We will need to know why. These are the initial questions that we have for you. Let us know if you have any questions from us. 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.   Initial questions on information sent to TRS Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Apr 8, 2016 at 2:22 PM   From: TRS <crisp@trs-integrity.com> To: TRS <crisp@trs-integrity.com> Sent: Friday, April 8, 2016 2:17 PM Subject: Re: Initial questions on information sent to TRS Hi Nicholas, Hope everything is going great for you. I also just waned to check and see how things are coming along with the email below and if you have any questions. Have a great weekend. 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.  From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Tuesday, March 29, 2016 1:40 PM Subject: Initial questions on information sent to TRS Hi Nicholas, Hope things are going well with you. I have been reviewing the information that you sent to us, and I have some initial questions that I would like to ask you: APPT Transactions Detail Report: What does these mean:  "Redacted - No subpoena was received,"  "Billed Amt." and "X Amt." What is the difference between the X Amt. and the Billed Amt.? What is the tax amount and how did you calculate it? Billing Platform Transaction Detail Report: What is: OTAPURCH, Enrollment, Recurring, BN Enrollment What is the tax amount and how did you calculate it? Telephone Accessories Custom Transaction - Level Detail : We are assuming this is equipment and/or accessories sold to customers.  On the reports that you sent to us, we also noticed these apparent discrepancies: In the information that was sent for the City of Tukwila, the amounts under Billing Platform Transaction Detail Report that you sent to us on 11/3/15 do not match up with the amounts that were sent to us on 3/7/16.  Also, there is an amount that is reported under the X amount for the email that you sent to us on 3/7/16 for the Billing Platform Transaction Detail Report, but there is no amount that is reported on the email that you sent to us on 11/3/15.  We will need to know why. In the City of Burien, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 11/30/15 and 2/25/16. This is also the case on the Billing Platform Customer Transaction Level Detail Report.  Also, there is an amount that is reported under the X amount for the Billing Platform Detail Report for the email that you sent to us on 2/25/16, but there is no amount that is reported on the email that you sent to us on 11/30/15.  We will need to know why. In the City of Kennewick, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 10/09/15 and 2/29/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Billing amount for 2/29/16, but there was a zero amount reported on the email that you sent to us on 10/09/15.   We also notice that you have a brand called Page Plus.  Are there sales happening for each brand in each city? If not, we will need to know why not. In the City of Spokane, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 7/02/15 and 3/4/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Tax amount for 3/4/16, but there was a zero amount reported on the email that you sent to us on 7/02/15.  We will need to know why. These are the initial questions that we have for you. Let us know if you have any questions from us. 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.  Fw: Initial questions on information sent to TRS Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Apr 21, 2016 at 3:03 PM Hi Nicholas, Just checking to see how things are coming along with our request below.  Could you also let me know that you have received this email (see below)?  If I don't receive anything back from you, I will try to telephone you next week. 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: Friday, April 8, 2016 2:22 PM Subject: Initial questions on information sent to TRS   From: TRS <crisp@trs-integrity.com> To: TRS <crisp@trs-integrity.com> Sent: Friday, April 8, 2016 2:17 PM Subject: Re: Initial questions on information sent to TRS Hi Nicholas, Hope everything is going great for you. I also just waned to check and see how things are coming along with the email below and if you have any questions. Have a great weekend. 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.  From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Tuesday, March 29, 2016 1:40 PM Subject: Initial questions on information sent to TRS Hi Nicholas, Hope things are going well with you. I have been reviewing the information that you sent to us, and I have some initial questions that I would like to ask you: APPT Transactions Detail Report: What does these mean:  "Redacted - No subpoena was received,"  "Billed Amt." and "X Amt." What is the difference between the X Amt. and the Billed Amt.? What is the tax amount and how did you calculate it? Billing Platform Transaction Detail Report: What is: OTAPURCH, Enrollment, Recurring, BN Enrollment What is the tax amount and how did you calculate it? Telephone Accessories Custom Transaction - Level Detail : We are assuming this is equipment and/or accessories sold to customers.  On the reports that you sent to us, we also noticed these apparent discrepancies: In the information that was sent for the City of Tukwila, the amounts under Billing Platform Transaction Detail Report that you sent to us on 11/3/15 do not match up with the amounts that were sent to us on 3/7/16.  Also, there is an amount that is reported under the X amount for the email that you sent to us on 3/7/16 for the Billing Platform Transaction Detail Report, but there is no amount that is reported on the email that you sent to us on 11/3/15.  We will need to know why. In the City of Burien, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 11/30/15 and 2/25/16. This is also the case on the Billing Platform Customer Transaction Level Detail Report.  Also, there is an amount that is reported under the X amount for the Billing Platform Detail Report for the email that you sent to us on 2/25/16, but there is no amount that is reported on the email that you sent to us on 11/30/15.  We will need to know why. In the City of Kennewick, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 10/09/15 and 2/29/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Billing amount for 2/29/16, but there was a zero amount reported on the email that you sent to us on 10/09/15.   We also notice that you have a brand called Page Plus.  Are there sales happening for each brand in each city? If not, we will need to know why not. In the City of Spokane, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 7/02/15 and 3/4/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Tax amount for 3/4/16, but there was a zero amount reported on the email that you sent to us on 7/02/15.  We will need to know why. These are the initial questions that we have for you. Let us know if you have any questions from us. 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: Initial questions on information sent to TRS Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Fri, Apr 22, 2016 at 12:04 PM Hi Mike – please see a series of my responses to your questions below in bold green font.  I’m still working on the remaining as indicated below as well in red font.   I have been reviewing the information that you sent to us, and I have some initial questions that I would like to ask you:   APPT Transactions Detail Report:   What does these mean:  "Redacted - No subpoena was received,"  "Billed Amt." and "X Amt."   "Redacted - No subpoena was received,"  -- pursuant to the Stored Communications Act (18 U.S.C. Sec. 2702), a holder, such as a telecommunications company, of a record or other information pertaining to a subscriber to or customer (customer name, address, telephone number, etc) cannot disclose this personal information to a governmental entity unless the governmental entity uses a subpoena or obtains a warrant, or court order.  Therefore, I used the phrase -- "Redacted - No subpoena was received,"  -- since no subpoena was received in respect to those cities under audit. What is the difference between the X Amt. and the Billed Amt.? X Amt. is the price that the customer was charged, whereas the Billed Amt. is the said price plus the taxes and fees shown in columns to the right of the Billed Amt.   What is the tax amount and how did you calculate it? Price that the customer was charged (or X Amt.) multiplied by the applicable tax rate. Billing Platform Transaction Detail Report: What is: OTAPURCH, Enrollment, Recurring, BN Enrollment   Still working on. What is the tax amount and how did you calculate it?   Price that the customer was charged (or X Amt.) multiplied by the applicable tax rate. Telephone Accessories Custom Transaction - Level Detail : We are assuming this is equipment and/or accessories sold to customers.  Yes. On the reports that you sent to us, we also noticed these apparent discrepancies: In the information that was sent for the City of Tukwila, the amounts under Billing Platform Transaction Detail Report that you sent to us on 11/3/15 do not match up with the amounts that were sent to us on 3/7/16.  Also, there is an amount that is reported under the X amount for the email that you sent to us on 3/7/16 for the Billing Platform Transaction Detail Report, but there is no amount that is reported on the email that you sent to us on 11/3/15.  We will need to know why.  Still working on.   In the City of Burien, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 11/30/15 and 2/25/16. This is also the case on the Billing Platform Customer Transaction Level Detail Report.  Also, there is an amount that is reported under the X amount for the Billing Platform Detail Report for the email that you sent to us on 2/25/16, but there is no amount that is reported on the email that you sent to us on 11/30/15.  We will need to know why.  Still working on.   In the City of Kennewick, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 10/09/15 and 2/29/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Billing amount for 2/29/16, but there was a zero amount reported on the email that you sent to us on 10/09/15.  Still working on.   We also notice that you have a brand called Page Plus.  Are there sales happening for each brand in each city? If not, we will need to know why not.  Still working on.   In the City of Spokane, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 7/02/15 and 3/4/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Tax amount for 3/4/16, but there was a zero amount reported on the email that you sent to us on 7/02/15.  We will need to know why.  Still working on.     These are the initial questions that we have for you.     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, April 21, 2016 6:04 PM To: Nicholas Ford Subject: Fw: Initial questions on information sent to TRS   Hi Nicholas, Just checking to see how things are coming along with our request below.  Could you also let me know that you have received this email (see below)?  If I don't receive anything back from you, I will try to telephone you next week. 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: Friday, April 8, 2016 2:22 PM Subject: Initial questions on information sent to TRS     From: TRS <crisp@trs-integrity.com>     To: TRS <crisp@trs-integrity.com> Sent: Friday, April 8, 2016 2:17 PM Subject: Re: Initial questions on information sent to TRS   Hi Nicholas,   Hope everything is going great for you.   I also just waned to check and see how things are coming along with the email below and if you have any questions.   Have a great weekend.   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.      From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Tuesday, March 29, 2016 1:40 PM Subject: Initial questions on information sent to TRS   Hi Nicholas, Hope things are going well with you.   I have been reviewing the information that you sent to us, and I have some initial questions that I would like to ask you:   APPT Transactions Detail Report:   What does these mean:  "Redacted - No subpoena was received,"  "Billed Amt." and "X Amt." What is the difference between the X Amt. and the Billed Amt.? What is the tax amount and how did you calculate it? Billing Platform Transaction Detail Report: What is: OTAPURCH, Enrollment, Recurring, BN Enrollment What is the tax amount and how did you calculate it? Telephone Accessories Custom Transaction - Level Detail : We are assuming this is equipment and/or accessories sold to customers.  On the reports that you sent to us, we also noticed these apparent discrepancies: In the information that was sent for the City of Tukwila, the amounts under Billing Platform Transaction Detail Report that you sent to us on 11/3/15 do not match up with the amounts that were sent to us on 3/7/16.  Also, there is an amount that is reported under the X amount for the email that you sent to us on 3/7/16 for the Billing Platform Transaction Detail Report, but there is no amount that is reported on the email that you sent to us on 11/3/15.  We will need to know why.   In the City of Burien, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 11/30/15 and 2/25/16. This is also the case on the Billing Platform Customer Transaction Level Detail Report.  Also, there is an amount that is reported under the X amount for the Billing Platform Detail Report for the email that you sent to us on 2/25/16, but there is no amount that is reported on the email that you sent to us on 11/30/15.  We will need to know why.   In the City of Kennewick, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 10/09/15 and 2/29/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Billing amount for 2/29/16, but there was a zero amount reported on the email that you sent to us on 10/09/15.     We also notice that you have a brand called Page Plus.  Are there sales happening for each brand in each city? If not, we will need to know why not.   In the City of Spokane, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 7/02/15 and 3/4/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Tax amount for 3/4/16, but there was a zero amount reported on the email that you sent to us on 7/02/15.  We will need to know why.   These are the initial questions that we have for you.   Let us know if you have any questions from us.   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: Initial questions on information sent to TRS Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Apr 22, 2016 at 12:37 PM Thanks Nicholas.  I will take a look at your email and will let you know if I have any questions. 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, April 22, 2016 12:04 PM Subject: RE: Initial questions on information sent to TRS Hi Mike – please see a series of my responses to your questions below in bold green font.  I’m still working on the remaining as indicated below as well in red font.   I have been reviewing the information that you sent to us, and I have some initial questions that I would like to ask you:   APPT Transactions Detail Report:   What does these mean:  "Redacted - No subpoena was received,"  "Billed Amt." and "X Amt."   "Redacted - No subpoena was received,"  -- pursuant to the Stored Communications Act (18 U.S.C. Sec. 2702), a holder, such as a telecommunications company, of a record or other information pertaining to a subscriber to or customer (customer name, address, telephone number, etc) cannot disclose this personal information to a governmental entity unless the governmental entity uses a subpoena or obtains a warrant, or court order.  Therefore, I used the phrase -- "Redacted - No subpoena was received,"  -- since no subpoena was received in respect to those cities under audit. What is the difference between the X Amt. and the Billed Amt.? X Amt. is the price that the customer was charged, whereas the Billed Amt. is the said price plus the taxes and fees shown in columns to the right of the Billed Amt.   What is the tax amount and how did you calculate it? Price that the customer was charged (or X Amt.) multiplied by the applicable tax rate. Billing Platform Transaction Detail Report: What is: OTAPURCH, Enrollment, Recurring, BN Enrollment   Still working on. What is the tax amount and how did you calculate it?   Price that the customer was charged (or X Amt.) multiplied by the applicable tax rate. Telephone Accessories Custom Transaction - Level Detail : We are assuming this is equipment and/or accessories sold to customers.  Yes. On the reports that you sent to us, we also noticed these apparent discrepancies: In the information that was sent for the City of Tukwila, the amounts under Billing Platform Transaction Detail Report that you sent to us on 11/3/15 do not match up with the amounts that were sent to us on 3/7/16.  Also, there is an amount that is reported under the X amount for the email that you sent to us on 3/7/16 for the Billing Platform Transaction Detail Report, but there is no amount that is reported on the email that you sent to us on 11/3/15.  We will need to know why.  Still working on.   In the City of Burien, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 11/30/15 and 2/25/16. This is also the case on the Billing Platform Customer Transaction Level Detail Report.  Also, there is an amount that is reported under the X amount for the Billing Platform Detail Report for the email that you sent to us on 2/25/16, but there is no amount that is reported on the email that you sent to us on 11/30/15.  We will need to know why.  Still working on.   In the City of Kennewick, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 10/09/15 and 2/29/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Billing amount for 2/29/16, but there was a zero amount reported on the email that you sent to us on 10/09/15.  Still working on.   We also notice that you have a brand called Page Plus.  Are there sales happening for each brand in each city? If not, we will need to know why not.  Still working on.   In the City of Spokane, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 7/02/15 and 3/4/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Tax amount for 3/4/16, but there was a zero amount reported on the email that you sent to us on 7/02/15.  We will need to know why.  Still working on.     These are the initial questions that we have for you.     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, April 21, 2016 6:04 PM To: Nicholas Ford Subject: Fw: Initial questions on information sent to TRS   Hi Nicholas, Just checking to see how things are coming along with our request below.  Could you also let me know that you have received this email (see below)?  If I don't receive anything back from you, I will try to telephone you next week. 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: Friday, April 8, 2016 2:22 PM Subject: Initial questions on information sent to TRS     From: TRS <crisp@trs-integrity.com>     To: TRS <crisp@trs-integrity.com> Sent: Friday, April 8, 2016 2:17 PM Subject: Re: Initial questions on information sent to TRS   Hi Nicholas,   Hope everything is going great for you.   I also just waned to check and see how things are coming along with the email below and if you have any questions.   Have a great weekend.   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.      From: TRS <crisp@trs-integrity.com> To: Nicholas Ford <nford@tracfone.com> Sent: Tuesday, March 29, 2016 1:40 PM Subject: Initial questions on information sent to TRS   Hi Nicholas, Hope things are going well with you.   I have been reviewing the information that you sent to us, and I have some initial questions that I would like to ask you:   APPT Transactions Detail Report:   What does these mean:  "Redacted - No subpoena was received,"  "Billed Amt." and "X Amt." What is the difference between the X Amt. and the Billed Amt.? What is the tax amount and how did you calculate it? Billing Platform Transaction Detail Report: What is: OTAPURCH, Enrollment, Recurring, BN Enrollment What is the tax amount and how did you calculate it? Telephone Accessories Custom Transaction - Level Detail : We are assuming this is equipment and/or accessories sold to customers.  On the reports that you sent to us, we also noticed these apparent discrepancies: In the information that was sent for the City of Tukwila, the amounts under Billing Platform Transaction Detail Report that you sent to us on 11/3/15 do not match up with the amounts that were sent to us on 3/7/16.  Also, there is an amount that is reported under the X amount for the email that you sent to us on 3/7/16 for the Billing Platform Transaction Detail Report, but there is no amount that is reported on the email that you sent to us on 11/3/15.  We will need to know why.   In the City of Burien, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 11/30/15 and 2/25/16. This is also the case on the Billing Platform Customer Transaction Level Detail Report.  Also, there is an amount that is reported under the X amount for the Billing Platform Detail Report for the email that you sent to us on 2/25/16, but there is no amount that is reported on the email that you sent to us on 11/30/15.  We will need to know why.   In the City of Kennewick, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 10/09/15 and 2/29/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Billing amount for 2/29/16, but there was a zero amount reported on the email that you sent to us on 10/09/15.     We also notice that you have a brand called Page Plus.  Are there sales happening for each brand in each city? If not, we will need to know why not.   In the City of Spokane, the amounts do not match up for the APPT Transaction Detail Report from the amounts that you sent to us on 7/02/15 and 3/4/16.  This is also the case on the Billing Platform Customer Transaciton Level Detail Report.  In addition, there was an amount that was reported under the Billing Platform Transaction Detail Report for the Tax amount for 3/4/16, but there was a zero amount reported on the email that you sent to us on 7/02/15.  We will need to know why.   These are the initial questions that we have for you.   Let us know if you have any questions from us.   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.    TracFone questons Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Apr 29, 2016 at 12:44 PM Hi Nicholas, Hope things have been going well with you. After reviewing your chart of accounts, some questions came up.  In your chart of accounts for revenues, we show that TracFone receives revenues for: Chart account number                                   Description 6102                                                    Airtime Revenue 6112                                                    Revenue - TF Service Protection 6113                                                    Revenue - Monthly Program 6118                                                    Revenue - Safelink Program 6202                                                    BYOP Revenue 6303                                                    Revenue - Other 6305                                                    Revenue - ILD Cards 6306                                                    Mobile Advertising Revenue Share 6308                                                    Revenue - Advertising Could you give us an explanation of what these revenues are, and which are included in the revenue lists you sent to us, and which are not, and if they are not, could you explain why they are not included? 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? Let me know if you have any questions. In addition, let me know if you have any questions concerning my request on my email sent to you on March 29, 2016. 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.    TracFone questons Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Mon, May 9, 2016 at 3:32 PM HI Nicholas, Hope all is well with you. I also just wanted to check and see how things are coming along with the email that I sent to you below. Let me 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: Friday, April 29, 2016 12:44 PM Subject: TracFone questons Hi Nicholas, Hope things have been going well with you. After reviewing your chart of accounts, some questions came up.  In your chart of accounts for revenues, we show that TracFone receives revenues for: Chart account number                                   Description 6102                                                    Airtime Revenue 6112                                                    Revenue - TF Service Protection 6113                                                    Revenue - Monthly Program 6118                                                    Revenue - Safelink Program 6202                                                    BYOP Revenue 6303                                                    Revenue - Other 6305                                                    Revenue - ILD Cards 6306                                                    Mobile Advertising Revenue Share 6308                                                    Revenue - Advertising Could you give us an explanation of what these revenues are, and which are included in the revenue lists you sent to us, and which are not, and if they are not, could you explain why they are not included? 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? Let me know if you have any questions. In addition, let me know if you have any questions concerning my request on my email sent to you on March 29, 2016. 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.  TracFone questons Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, May 19, 2016 at 3:40 PM Hi Nicholas, Just wanted to check and see how things are coming along with the information that we requested below. Let us know if you have any questions. Thanks Nicholas for all of your help. 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: Monday, May 9, 2016 3:32 PM Subject: TracFone questons HI Nicholas, Hope all is well with you. I also just wanted to check and see how things are coming along with the email that I sent to you below. Let me 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: Friday, April 29, 2016 12:44 PM Subject: TracFone questons Hi Nicholas, Hope things have been going well with you. After reviewing your chart of accounts, some questions came up.  In your chart of accounts for revenues, we show that TracFone receives revenues for: Chart account number                                   Description 6102                                                    Airtime Revenue 6112                                                    Revenue - TF Service Protection 6113                                                    Revenue - Monthly Program 6118                                                    Revenue - Safelink Program 6202                                                    BYOP Revenue 6303                                                    Revenue - Other 6305                                                    Revenue - ILD Cards 6306                                                    Mobile Advertising Revenue Share 6308                                                    Revenue - Advertising Could you give us an explanation of what these revenues are, and which are included in the revenue lists you sent to us, and which are not, and if they are not, could you explain why they are not included? 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? Let me know if you have any questions. In addition, let me know if you have any questions concerning my request on my email sent to you on March 29, 2016. 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.  Question concerning the audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, May 19, 2016 at 4:23 PM Hi Nicholas, I forgot to mention to you about a question that we had emailed January 8, 2016 for which we did not receive a reply:  Does the data you have sent to us regarding the billing sales include the sales done by Walmart and other retailers? Let us know if you have any questions. 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 RE: Question concerning the audit Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Fri, May 20, 2016 at 10:40 AM Hi Mike – please see my response (inserted) to your question 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: Thursday, May 19, 2016 7:23 PM To: Nicholas Ford Subject: Question concerning the audit   Hi Nicholas,   I forgot to mention to you about a question that we had emailed January 8, 2016 for which we did not receive a reply:  Does the data you have sent to us regarding the billing sales include the sales done by Walmart and other retailers?  No, the data does not.   Let us know if you have any questions.   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.   Re: Question concerning the audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, May 20, 2016 at 11:29 AM Thanks Nicholas for the answer.  Let me know if you have any questions with the other request. 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, May 20, 2016 10:40 AM Subject: RE: Question concerning the audit Hi Mike – please see my response (inserted) to your question 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: Thursday, May 19, 2016 7:23 PM To: Nicholas Ford Subject: Question concerning the audit   Hi Nicholas,   I forgot to mention to you about a question that we had emailed January 8, 2016 for which we did not receive a reply:  Does the data you have sent to us regarding the billing sales include the sales done by Walmart and other retailers?  No, the data does not.   Let us know if you have any questions.   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.  Question concerning the audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, May 25, 2016 at 4:38 PM Hi Nicholas, Hope all is well with you. 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? 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. 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: Tuesday, May 24, 2016 4:08 PM Subject: Re: Question concerning the audit Hi Nicholas, Thanks again for your response. 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?  And if so, could you tell us the percentage of your revenues that come from your stores versus the revenues that come from other stores?  And if the revenues you sent to us do not come from your stores, then could you tell us what they are for, specifically? Also, we wanted to check and see about the other email that we sent to you (on April 29 of this year) concerning other revenue items on your chart of accounts, and if you are receiving revenues for these items, and if they are included in the revenue figures that you sent to us. Let us know if you have any questions. Thanks Nicholas for all of your help. 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: Friday, May 20, 2016 10:40 AM Subject: RE: Question concerning the audit Hi Mike – please see my response (inserted) to your question 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: Thursday, May 19, 2016 7:23 PM To: Nicholas Ford Subject: Question concerning the audit   Hi Nicholas,   I forgot to mention to you about a question that we had emailed January 8, 2016 for which we did not receive a reply:  Does the data you have sent to us regarding the billing sales include the sales done by Walmart and other retailers?  No, the data does not.   Let us know if you have any questions.   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.  Re: Question concerning the audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Tue, May 24, 2016 at 4:08 PM Hi Nicholas, Thanks again for your response. 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?  And if so, could you tell us the percentage of your revenues that come from your stores versus the revenues that come from other stores?  And if the revenues you sent to us do not come from your stores, then could you tell us what they are for, specifically? Also, we wanted to check and see about the other email that we sent to you (on April 29 of this year) concerning other revenue items on your chart of accounts, and if you are receiving revenues for these items, and if they are included in the revenue figures that you sent to us. Let us know if you have any questions. Thanks Nicholas for all of your help. 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: Friday, May 20, 2016 10:40 AM Subject: RE: Question concerning the audit Hi Mike – please see my response (inserted) to your question 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: Thursday, May 19, 2016 7:23 PM To: Nicholas Ford Subject: Question concerning the audit   Hi Nicholas,   I forgot to mention to you about a question that we had emailed January 8, 2016 for which we did not receive a reply:  Does the data you have sent to us regarding the billing sales include the sales done by Walmart and other retailers?  No, the data does not.   Let us know if you have any questions.   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.  Question concerning the audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, May 25, 2016 at 4:38 PM Hi Nicholas, Hope all is well with you. 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? 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. 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: Tuesday, May 24, 2016 4:08 PM Subject: Re: Question concerning the audit Hi Nicholas, Thanks again for your response. 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?  And if so, could you tell us the percentage of your revenues that come from your stores versus the revenues that come from other stores?  And if the revenues you sent to us do not come from your stores, then could you tell us what they are for, specifically? Also, we wanted to check and see about the other email that we sent to you (on April 29 of this year) concerning other revenue items on your chart of accounts, and if you are receiving revenues for these items, and if they are included in the revenue figures that you sent to us. Let us know if you have any questions. Thanks Nicholas for all of your help. 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: Friday, May 20, 2016 10:40 AM Subject: RE: Question concerning the audit Hi Mike – please see my response (inserted) to your question 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: Thursday, May 19, 2016 7:23 PM To: Nicholas Ford Subject: Question concerning the audit   Hi Nicholas,   I forgot to mention to you about a question that we had emailed January 8, 2016 for which we did not receive a reply:  Does the data you have sent to us regarding the billing sales include the sales done by Walmart and other retailers?  No, the data does not.   Let us know if you have any questions.   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.  Question concerning the audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Jun 1, 2016 at 2:27 PM Hi Nicholas, Just wanted to check and see how things are coming along with the questions and and information that we requested below. Let me know if you have any questions. Thanks Nichols. 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: Wednesday, May 25, 2016 4:38 PM Subject: Question concerning the audit Hi Nicholas, Hope all is well with you. 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? 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. 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: Tuesday, May 24, 2016 4:08 PM Subject: Re: Question concerning the audit Hi Nicholas, Thanks again for your response. 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?  And if so, could you tell us the percentage of your revenues that come from your stores versus the revenues that come from other stores?  And if the revenues you sent to us do not come from your stores, then could you tell us what they are for, specifically? Also, we wanted to check and see about the other email that we sent to you (on April 29 of this year) concerning other revenue items on your chart of accounts, and if you are receiving revenues for these items, and if they are included in the revenue figures that you sent to us. Let us know if you have any questions. Thanks Nicholas for all of your help. 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: Friday, May 20, 2016 10:40 AM Subject: RE: Question concerning the audit Hi Mike – please see my response (inserted) to your question 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: Thursday, May 19, 2016 7:23 PM To: Nicholas Ford Subject: Question concerning the audit   Hi Nicholas,   I forgot to mention to you about a question that we had emailed January 8, 2016 for which we did not receive a reply:  Does the data you have sent to us regarding the billing sales include the sales done by Walmart and other retailers?  No, the data does not.   Let us know if you have any questions.   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.  RE: Question concerning the audit Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Thu, Jun 2, 2016 at 10:54 AM Hi Mike – we are in the midst of our month-end closing.  I should be able to respond to at least a few of your outstanding questions 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: Wednesday, June 01, 2016 5:28 PM To: Nicholas Ford Subject: Question concerning the audit   Hi Nicholas,   Just wanted to check and see how things are coming along with the questions and and information that we requested below. Let me know if you have any questions. Thanks Nichols. 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: Wednesday, May 25, 2016 4:38 PM Subject: Question concerning the audit   Hi Nicholas,   Hope all is well with you.   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?   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. 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: Tuesday, May 24, 2016 4:08 PM Subject: Re: Question concerning the audit   Hi Nicholas,   Thanks again for your response.   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?  And if so, could you tell us the percentage of your revenues that come from your stores versus the revenues that come from other stores?  And if the revenues you sent to us do not come from your stores, then could you tell us what they are for, specifically?   Also, we wanted to check and see about the other email that we sent to you (on April 29 of this year) concerning other revenue items on your chart of accounts, and if you are receiving revenues for these items, and if they are included in the revenue figures that you sent to us.   Let us know if you have any questions.   Thanks Nicholas for all of your help.   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: Friday, May 20, 2016 10:40 AM Subject: RE: Question concerning the audit   Hi Mike – please see my response (inserted) to your question 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: Thursday, May 19, 2016 7:23 PM To: Nicholas Ford Subject: Question concerning the audit   Hi Nicholas,   I forgot to mention to you about a question that we had emailed January 8, 2016 for which we did not receive a reply:  Does the data you have sent to us regarding the billing sales include the sales done by Walmart and other retailers?  No, the data does not.   Let us know if you have any questions.   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.        Re: Question concerning the audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Jun 2, 2016 at 1:04 PM Thanks Nicholas.  I do appreciate all of your help. 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: Thursday, June 2, 2016 10:54 AM Subject: RE: Question concerning the audit Hi Mike – we are in the midst of our month-end closing.  I should be able to respond to at least a few of your outstanding questions 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: Wednesday, June 01, 2016 5:28 PM To: Nicholas Ford Subject: Question concerning the audit   Hi Nicholas,   Just wanted to check and see how things are coming along with the questions and and information that we requested below. Let me know if you have any questions. Thanks Nichols. 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: Wednesday, May 25, 2016 4:38 PM Subject: Question concerning the audit   Hi Nicholas,   Hope all is well with you.   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?   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. 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: Tuesday, May 24, 2016 4:08 PM Subject: Re: Question concerning the audit   Hi Nicholas,   Thanks again for your response.   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?  And if so, could you tell us the percentage of your revenues that come from your stores versus the revenues that come from other stores?  And if the revenues you sent to us do not come from your stores, then could you tell us what they are for, specifically?   Also, we wanted to check and see about the other email that we sent to you (on April 29 of this year) concerning other revenue items on your chart of accounts, and if you are receiving revenues for these items, and if they are included in the revenue figures that you sent to us.   Let us know if you have any questions.   Thanks Nicholas for all of your help.   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: Friday, May 20, 2016 10:40 AM Subject: RE: Question concerning the audit   Hi Mike – please see my response (inserted) to your question 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: Thursday, May 19, 2016 7:23 PM To: Nicholas Ford Subject: Question concerning the audit   Hi Nicholas,   I forgot to mention to you about a question that we had emailed January 8, 2016 for which we did not receive a reply:  Does the data you have sent to us regarding the billing sales include the sales done by Walmart and other retailers?  No, the data does not.   Let us know if you have any questions.   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.    TracFone Audit Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Jun 10, 2016 at 12:29 PM 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 Fri, Jun 17, 2016 at 8:34 AM   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 Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Jun 17, 2016 at 1:08 PM Thanks Nicholas for the email.  We will review it and will get back with you if we have any questions. 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 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 Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Jun 17, 2016 at 1:08 PM Thanks Nicholas for the email.  We will review it and will get back with you if we have any questions. 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 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 Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Tue, Jun 21, 2016 at 2:00 PM 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?" 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.  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)? 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. 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 Fri, Jun 24, 2016 at 8:06 AM   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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Jun 24, 2016 at 1:34 PM 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 - Responses Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Tue, Jun 28, 2016 at 12:25 PM   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         31% 1,658,066,825 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% 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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Tue, Jun 28, 2016 at 2:05 PM Thanks Nicholas.  We will take a look at your email and will let you know if we have any questions. Let us know if you have any questions on the April 29th email we sent to you. 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: 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% 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% 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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Jun 30, 2016 at 4:08 PM 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% 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%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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Jul 8, 2016 at 2:01 PM 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% 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%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.      Fw: TracFone Audit Questions - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Tue, Jul 12, 2016 at 2:08 PM 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% 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%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 - Responses Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Tue, Jul 19, 2016 at 2:40 PM 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% 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% 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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Jul 20, 2016 at 11:55 AM Thanks Nicholas.  That sounds good. 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.     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% 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% 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 - Responses Inbox  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Jul 28, 2016 at 5:00 PM 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% 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% 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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Thu, Aug 4, 2016 at 3:01 PM 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% 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% 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 - Responses Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Fri, Aug 5, 2016 at 7:39 AM 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% 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% 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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Aug 5, 2016 at 12:35 PM Thanks Nicholas.  That sounds great. 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, 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% 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% 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 - Responses Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Wed, Aug 17, 2016 at 11:12 AM   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% 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% 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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Aug 17, 2016 at 2:01 PM 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% 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% 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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Aug 24, 2016 at 2:41 PM Hi Nicholas, Just checking to see how things are coming along with the question concerning the retail sales and wholesale sales. Let us know if you have any questions. We are also reviewing the definition of different revenues for your company that you sent to us and will let you know if we have any questions.  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.  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% 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% 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 - Responses Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Fri, Aug 26, 2016 at 10:35 AM   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% (2) Net Airtime Revenue (Per Financial Statements)                                  2,457,761,508 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             341,243,35 1 Total (2) + (3):                                 2,799,004,859  Company-Wide 1 minus Retail Percentage =83% 2011 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                           793,674,906 21% (2) Net Airtime Revenue (Per Financial Statements)                                  3,433,624,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             380,952,00 0 Total (2) + (3):                                 3,814,576,000  Company-Wide 1 - Retail Percentage =79% 2012 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 1,164,915,001 24% (2) Net Airtime Revenue (Per Financial Statements)                                  4,291,440,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             502,534,00 0 Total (2) + (3):                                 4,793,974,000  Company-Wide 1 - Retail Percentage =76% 2013 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 1,658,066,825 27% (2) Net Airtime Revenue (Per Financial Statements)                                  5,358,599,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             676,091,00 0 Total (2) + (3):                                 6,034,690,000  Company-Wide 1 - Retail Percentage =73% 2014 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 2,144,494,356 31% (2) Net Airtime Revenue (Per Financial Statements)                                  6,126,893,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             694,099,00 0 Total (2) + (3):                                 6,820,992,000  Company-Wide 1 - Retail Percentage =69% 2015 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 2,330,936,554 33% (2) Net Airtime Revenue (Per Financial Statements)                                  6,279,204,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             699,462,00 0 Total (2) + (3):                                 6,978,666,000  Company-Wide 1 - Retail Percentage =67%   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% 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% 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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Aug 24, 2016 at 2:41 PM Hi Nicholas, Just checking to see how things are coming along with the question concerning the retail sales and wholesale sales. Let us know if you have any questions. We are also reviewing the definition of different revenues for your company that you sent to us and will let you know if we have any questions.  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.  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% 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% 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 RE: TracFone Audit Questions - Responses Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Fri, Aug 26, 2016 at 10:35 AM   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% (2) Net Airtime Revenue (Per Financial Statements)                                  2,457,761,508 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             341,243,35 1 Total (2) + (3):                                 2,799,004,859  Company-Wide 1 minus Retail Percentage =83% 2011 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                           793,674,906 21% (2) Net Airtime Revenue (Per Financial Statements)                                  3,433,624,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             380,952,00 0 Total (2) + (3):                                 3,814,576,000  Company-Wide 1 - Retail Percentage =79% 2012 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 1,164,915,001 24% (2) Net Airtime Revenue (Per Financial Statements)                                  4,291,440,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             502,534,00 0 Total (2) + (3):                                 4,793,974,000  Company-Wide 1 - Retail Percentage =76% 2013 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 1,658,066,825 27% (2) Net Airtime Revenue (Per Financial Statements)                                  5,358,599,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             676,091,00 0 Total (2) + (3):                                 6,034,690,000  Company-Wide 1 - Retail Percentage =73% 2014 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 2,144,494,356 31% (2) Net Airtime Revenue (Per Financial Statements)                                  6,126,893,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             694,099,00 0 Total (2) + (3):                                 6,820,992,000  Company-Wide 1 - Retail Percentage =69% 2015 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 2,330,936,554 33% (2) Net Airtime Revenue (Per Financial Statements)                                  6,279,204,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             699,462,00 0 Total (2) + (3):                                 6,978,666,000  Company-Wide 1 - Retail Percentage =67%   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% 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% 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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Fri, Aug 26, 2016 at 4:09 PM Thanks Nicholas for the information.  We will review it and will let you know if we have any questions. 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, 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%(2) Net Airtime Revenue (Per Financial Statements)                                  2,457,761,508 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             341,243,35 1 Total (2) + (3):                                 2,799,004,859  Company-Wide 1 minus Retail Percentage =83% 2011 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                           793,674,906 21%(2) Net Airtime Revenue (Per Financial Statements)                                  3,433,624,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             380,952,00 0 Total (2) + (3):                                 3,814,576,000  Company-Wide 1 - Retail Percentage =79% 2012 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 1,164,915,001 24% (2) Net Airtime Revenue (Per Financial Statements)                                  4,291,440,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             502,534,00 0 Total (2) + (3):                                 4,793,974,000  Company-Wide 1 - Retail Percentage =76% 2013 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 1,658,066,825 27% (2) Net Airtime Revenue (Per Financial Statements)                                  5,358,599,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             676,091,00 0 Total (2) + (3):                                 6,034,690,000  Company-Wide 1 - Retail Percentage =73% 2014 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 2,144,494,356 31% (2) Net Airtime Revenue (Per Financial Statements)                                  6,126,893,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             694,099,00 0 Total (2) + (3):                                 6,820,992,000  Company-Wide 1 - Retail Percentage =69% 2015 (1) Retail (Direct) Sales Amounts (Airtime & Phones) Company-Wide                                                                 2,330,936,554 33% (2) Net Airtime Revenue (Per Financial Statements)                                  6,279,204,000 (3) Net Phones & Accessories Revenue (Per Financial Statements)                                                                             699,462,00 0 Total (2) + (3):                                 6,978,666,000  Company-Wide 1 - Retail Percentage =67%   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% 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% 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 - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Aug 31, 2016 at 1:15 PM Hi Nicholas, Thanks for the email.  We will review it and will get back with you if we have any questions. Also, how things are coming along with the question concerning the retail sales and wholesale sales. 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: Tuesday, August 30, 2016 1:26 PM Subject: RE: TracFone Audit Questions - Responses 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% 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% 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 - Responses Inbox  Nicholas Ford <nford@tracfone.com> To:crisp@trs-integrity.com Wed, Aug 31, 2016 at 1:25 PM Hi Mike – concerning the retail and wholesale sales questions, please see my 8/26/16 reply e-mail.   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 31, 2016 4:16 PM To: Nicholas Ford Subject: Re: TracFone Audit Questions - Responses   Hi Nicholas,   Thanks for the email.  We will review it and will get back with you if we have any questions.   Also, how things are coming along with the question concerning the retail sales and wholesale sales. 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: Tuesday, August 30, 2016 1:26 PM Subject: RE: TracFone Audit Questions - Responses   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 audit s.  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% Airtime Revenue (Per Financial Statements) Company-Wide      5,358,559,000 69% 2014 Direct Sales Amounts (Per Accum. Summary Reports for '14) Company-Wide         2,144,494,356 35% Airtime Revenue (Per Financial Statements) Company-Wide      6,126,893,000 65%   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.                       Fw: TracFone Audit Questions - Responses Sent  TRS <crisp@trs-integrity.com> To:nford@tracfone.com Wed, Aug 31, 2016 at 1:26 PM Hi Nicholas, I forgot about the August 26th email you sent to us concerning retail and wholesale sales.  So no need to send an email concerning these sales.  We will let you know if we have any questions. Thanks, 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, August 31, 2016 1:15 PM Subject: Re: TracFone Audit Questions - Responses Hi Nicholas, Thanks for the email.  We will review it and will get back with you if we have any questions. Also, how things are coming along with the question concerning the retail sales and wholesale sales. 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: Tuesday, August 30, 2016 1:26 PM Subject: RE: TracFone Audit Questions - Responses 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% Airtime Revenue (Per Financial Statements) Company-Wide      5,358,559,000 69% 2014 Direct Sales Amounts (Per Accum. Summary Reports for '14) Company-Wide         2,144,494,356 35% Airtime Revenue (Per Financial Statements) Company-Wide      6,126,893,000 65%   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.                    