Read Letitia James’s Lawsuit Against Donald Trump

Page 118 of 222

CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/21/2022 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system’s electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings accepted for for various filing reasons, by the County readers Clerk. should be aware that documents bearing this legend may not have been 118 of 222 the chart below: facts and assumptions that were materially false and misleading, were known by Mr. Trump and others within the Trump Organization to be materially false and misleading, and which substantially inflated the valuations as described more fully below. contributions since the inception of his ownership adjusted by a “multiplier,”4 which is a fixed- assets approach, and without factoring in any depreciation – hereafter referred to as the “Fixed- Assets Scheme.” But using fixed assets to derive the market value of a golf course is contrary to industry custom and practice, as Mr. Trump himself acknowledged to the IRS in 2012 when 4 The capital contributions were multiplied by a 30% premium for the assembly of land parcels. 398. These components and the total value of the property in each year are set forth in 399. Both components were derived each year using improper methods and based on 400. In each year, Mr. Trump derived the value of the golf course based on his capital Statement Year 2011 $41,000,000 $119,000,000 $160,000,000 2012 $64,703,600 $117,600,000 $182,303,600 2013 $76,715,600 $114,450,000 $191,165,600 2014 $74,169,082 $361,393,344 $435,562,426 2015 $60,570,463 $267,016,090 $327,586,553 2016 $50,679,806 $226,043,750 $276,723,556 2017 $49,691,890 $221,155,584 $270,847,474 2018 $50,832,046 $223,217,779 $274,049,825 2019 $49,460,737 $220,989,724 $270,450,461 2020 $38,355,969 $101,272,826 $139,628,795 2021 $21,012,667 $114,317,896 $135,330,563 Value of Golf Course Value of Undeveloped Land i. The Golf Course Valuations 111 Total Value

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