led to the same TRA payments upon making exchanges of AOG units for Apollo Class A stock that Leon 3 These percentages were arrived at by applying Leon's Sharing Percentage (44%) and Heritage Points Percentages (71% for Fund IV and 55% for Fund V) under the Agreement Among Principals to the 47.79% of

New York State Transfer Tax (paid by seller) and the Community Preservation Fund Tax (a/k/a the Peconic Tax paid by buyer). I posed this question to Leon's Long Island attorney who consulted with the title company. According to counsel for the title company, Leon and Debra's receipt of the membership in