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which is responsible for overseeing tax compliance and reporting for an extremely complex business enterprise, and by Apollo's then tax advisors at Ernst & Young, which prepared the applicable Schedule K-1. Basis for Reasonable Cause The Taxpayers have exercised ordinary business care and prudence by engagi
n corporations and foreign disregarded entities (the "Foreign Entities") listed on the enclosed Exhibit A. The Foreign Entities, other than BRH and AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate Apollo entities timely and properly filed the Forms 8865 and 8858 with respect to t
t, which is responsible for overseeing tax compliance and reporting for an extremely complex business enterprise, and Apollo's then tax advisors at Ernst & Young, which prepared the applicable Schedule K-1. Basis for Reasonable Cause The Taxpayers have exercised ordinary business care and prudence by engagi
rations and foreign disregarded entities (the "Foreign Entities") listed on the enclosed Exhibit A. The Foreign Entities related to BRH, other than AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate Apollo entities timely and properly filed the Forms 8865 and 8858 with respect to t
which is responsible for overseeing tax compliance and reporting for an extremely complex business enterprise, and by Apollo's then tax advisors at Ernst & Young, which prepared the applicable Schedule K-1. Basis for Reasonable Cause The Taxpayers have exercised ordinary business care and prudence by engagi
rations and foreign disregarded entities (the "Foreign Entities") listed on the enclosed Exhibit A. The Foreign Entities related to BRH, other than AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate Apollo entities timely and properly filed the Forms 8865 and 8858 with respect to t
Entities connected to both Ernst & Young and AP Professional Holdings LP
Leon Black
PERSON
Deloitte
ORGANIZATIONthe Internal Revenue Service's
ORGANIZATIONthe "Partnership"
ORGANIZATIONPaul, Weiss, Rifkind
ORGANIZATIONthe Foreign Entities
ORGANIZATIONDebra Black
PERSONTaxpayers
ORGANIZATIONAAA ASSOCIATES LP
ORGANIZATIONDelinquent International Information Return Submission Procedures
ORGANIZATIONAAA GUERNSEY LIMITED
ORGANIZATIONAPO FC-GP
ORGANIZATIONAPOLLO ADVISORS VII
ORGANIZATIONAPOLLO PRINCIPAL HOLDINGS VIII LP
ORGANIZATIONAPOLLO SOMA II ADVISORS LP
ORGANIZATIONSCOTS GP LTD
ORGANIZATION
Oliver Stone
PERSONNon-BRH Related Entity
ORGANIZATION
Konigsberg
PERSONBRH HOLDINGS LP
ORGANIZATION