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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
any obligation to file the International Information Returns with respect to BRH or the many other Foreign Entities held through BRH. In addition, the Foreign Entities are indirectly or constructively owned, in whole or in part, by BRH, and the tax information of such Foreign Entities is not directly reported to th
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
n LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the Foreign Entities, including the Non- BRH Related Entities, for 2008, which the Taxpayers are now doing via the filing of the Amended Return. The Taxpayers are neith
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 LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the Foreign Entities, including the Non- BRH Related Entities, for 2007, which the Taxpayers are now doing via the filing of the Amended Return. The Taxpayers are neith
Entities connected to both Ernst & Young and the Foreign Entities
Leon Black
PERSON
Deloitte
ORGANIZATIONthe Internal Revenue Service's
ORGANIZATIONthe "Partnership"
ORGANIZATIONAP Professional Holdings LP
ORGANIZATIONPaul, Weiss, Rifkind
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