EFTA00590766.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 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"

"the Partnership's tax advisors at Ernst & Young who prepared the applicable Schedule K-1"

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