EFTA00584470.txt

"Deloitte (Apollo's tax advisor)"

"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"

"The Foreign Entities related to BRH, other than AP Professional Holdings LP, are also owned, in part, indirectly by Apollo."

"The Original Return, the Amended Return and the accompanying International Information Returns were prepared by the Taxpayers' professional accountant"

"The Original Return, the Amended Return and the accompanying International Information Returns were prepared by the Taxpayers' professional accountant"

"diligently reviewed the history and factual circumstances with their accountants and the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP"