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-

014, 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 Malter & Co. LLP ("REM-Co"). Background The Taxpayers own interests in a wide variety of entities relatecH

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

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

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

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

reported by the Taxpayers, or in the tax liability owed by the Taxpayers, for 2008, which was timely paid. The Original Return was prepared by the Taxpayers' professional accountants at Konigsberg Wolf & Co., P.C. ("Konigsberg"), and the Amended Return along with the accompanying International Informati

reported by the Taxpayers, or in the tax liability owed by the Taxpayers, for 2007, which was timely paid. The Original Return was prepared by the Taxpayers' professional accountants at Konigsberg Wolf & Co., P.C. ("Konigsberg"), and the Amended Return along with the accompanying International Informati