EFTA00584483.txt

"The Taxpayers own interests in a wide variety of entities related to Apollo Global Management, LLC ("Apollo") ... through their interest in BRH Holdin"

"The Taxpayers own interests in a wide variety of entities related to Apollo Global Management, LLC ("Apollo") ... through their interest in BRH Holdin"

"Deloitte (Apollo's current tax advisor)"

"Apollo's then tax advisors at Ernst & Young"

"employees of Apollo have assisted with the preparation of the tax returns of BRH"

"the accompanying International Information Returns were prepared by the Taxpayers' professional accountants at Raich Ende Malter & Co. LLP"

"the accompanying International Information Returns were prepared by the Taxpayers' professional accountants at Raich Ende Malter & Co. LLP"