EFTA00590772.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"

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

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

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

"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... through their interest in BRH Holdings"