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012, which was timely paid. The Original Return, the Amended Return and the accompanying International Information Returns were all prepared by the Taxpayers' professional accountants at Raich Ende Matter & Co. LLP ("REM-Co"). Background The Taxpayers own interests in a wide variety of entities related-
their tax advisors, but-instead-is-relled-inte-the-tax-reperting-ef-BRI4. As a result, neither the Taxpayers nor their professional accountants at REM-Co were aware that these filings were required and, in any case, they were not provided the information necessary to have properly eempletecomnleted t
een subject to tax penalties. The Taxpayers are not under a civil examination or a criminal investigation by the IRS. The IRS has not contacted the Taxpayers about any of the delinquent International Information Returns that are the subject of this submission. The Foreign Entities that are the subject of
or their tax advisors, but instead is rolled into the tax reporting of BRH. As a result, neither the Taxpayers nor their professional accountants at REM-Co were aware that these filings were required and, in any case, they were not provided the information necessary to EFTA00584477 properly complete
een subject to tax penalties. The Taxpayers are not under a civil examination or a criminal investigation by the IRS. The IRS has not contacted the Taxpayers about any of the delinquent International Information Returns that are the subject of this submission. The Foreign Entities that are the subject of
he Taxpayers or their tax advisors, but instead is rolled into the tax reporting of BRH. As a result, neither the Taxpayers nor their accountants at REM-Co were aware that any other International Information Return filings were required and, in any case, they were not provided the information necessary
een subject to tax penalties. The Taxpayers are not under a civil examination or a criminal investigation by the IRS. The IRS has not contacted the Taxpayers about any of the delinquent International Information Returns that are the subject of this submission. The Foreign Entities that are the subject of
or their tax advisors, but instead is rolled into the tax reporting of BRH. As a result, neither the Taxpayers nor their professional accountants at REM-Co were aware that these filings were required and, in any case, they were not provided the information necessary to EFTA00584470 properly complete
een subject to tax penalties. The Taxpayers are not under a civil examination or a criminal investigation by the IRS. The IRS has not contacted the Taxpayers about any of the delinquent International Information Returns that are the subject of this submission. The Foreign Entities that are the subject of
r their tax advisors, but instead is rolled into the tax reporting of BRH. As a result, neither the Taxpayers nor their professional accountants at REM-Co were aware that these filings were required and, in any case, they were not provided the information necessary to properly complete the EFTA0058448
Entities connected to both Taxpayers and REM-Co
the Foreign Entities
ORGANIZATIONLeon Black
PERSON
Deloitte
ORGANIZATIONPaul, Weiss, Rifkind
ORGANIZATIONDebra Black
PERSONthe Internal Revenue Service's
ORGANIZATIONthe "Partnership"
ORGANIZATIONAP Professional Holdings LP
ORGANIZATIONAAA GUERNSEY LIMITED
ORGANIZATIONAAA ASSOCIATES LP
ORGANIZATIONDelinquent International Information Return Submission Procedures
ORGANIZATIONAPOLLO ADVISORS VII
ORGANIZATIONWharton & Garrison LLP
ORGANIZATIONForms 5471
ORGANIZATIONAPOLLO SOMA II ADVISORS LP
ORGANIZATIONAPO FC-GP
ORGANIZATIONAPOLLO PRINCIPAL HOLDINGS VIII LP
ORGANIZATIONAPOLLO EPF CAPITAL MANAGEMENT LIMITED
ORGANIZATIONRaich Ende Malter & Co. LLP
ORGANIZATIONADIC LIFE ADVISORS LP
ORGANIZATION