EFTA00590759.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... through their interest in BRH Holdings, M."

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

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

"Amended Return... were prepared by the Taxpayers' professional accountants at Raich Ende Malter & Co. LLP"

"Amended Return... were prepared by the Taxpayers' professional accountants at Raich Ende Malter & Co. LLP"

"the Partnership's tax advisors at Deloitte who prepared the applicable Schedule K-1"