EFTA00605295.txt

"Taxpayers, husband and wife, are hereby voluntarily filing"

"The Taxpayers own interests in a wide variety of entities related-teaffiliated with Apollo Global Management, LLC ("Apollo") ... through their interes"

"The Taxpayers own interests in a wide variety of entities related-teaffiliated with Apollo Global Management, LLC ("Apollo") ... through their interes"

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

"Deloitte (Apollo's tax advisor)"

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

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

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

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