EFTA00590604.txt

"Leon and Debra Black (the 'Taxpayers afe, husband and wife"

"The Taxpayers became partners in BRH in 2007, the year in which it was formed."

"The Taxpayers became partners in BRH in 2007, the year in which it was formed."

"Foreign Entities related to BRH are also owned, in part, indirectly by Apollo."

"Apollo's tax advisors at Ernst & Young-who, which prepared the applicable Schedule K-1."

"the Taxpayers and their representatives were first informed... by Apollo's tax department; that the Taxpayers likely had an obligation to file the Int"

"The Original Return was prepared by the Taxpayers' professional accountants at Konigsberg Wolf & Co."

"the Amended Return along with the accompanying International Information Returns were prepared by the same accountants who are now at Raich Ende Malte"