EFTA00590779.txt

"Leon and Debra Black, (the "Taxpayers"), are husband and wife"

"The Taxpayers are indirect owners of a wide variety of entities related to Apollo Global Management, LLC ("Apollo") ... through their interest in BRH "

"The Taxpayers are indirect owners of a wide variety of entities related to Apollo Global Management, LLC ("Apollo") ... through their interest in BRH "

"the Partnership's tax advisors at Ernst & Young who prepared the applicable Schedule K-I"

"all of the Foreign Entities related to ApelleBRH are indirectly or constructively owned, in whole or in part, by BRH"

"all of the Foreign Entities related to ApelleBRH are indirectly or constructively owned, in whole or in part, by BRH"

"The Original Return was prepared by the Taxpayers' professional accountants at Konigsberg Wolf & Co."

"The Original Return was prepared by the Taxpayers' professional accountants at Konigsberg Wolf & Co."

"the Amended Return along with the accompanying International Information Returns were prepared by the same accountants who are now at Raich Ende Malte"

"the Amended Return along with the accompanying International Information Returns were prepared by the same accountants who are now at Raich Ende Malte"