From: Thomas Turrin To: "Barry J. Cohen" CC: jeffrey E. <[email protected]>, " Black <I Subject: RE: IRS Date: Sun, 30 Apr 2017 23:49:12 +0000 >, Leon Yes....given that other execs at Apollo also received assessments, it's highly likely that the BRH adjustment resulted from an audit of entities downstream from BRH. What I don't know is how the statute of limitations was extended to keep 2012 open. Typically a waiver is requested by IRS to extend statute so that it has time to conclude its audit. Such waiver would be signed by the tax matters partner or someone with internal authority at Apollo to sign such a waiver on behalf of the partnership being examined. It is very typical that a waiver to extend statute would be requested on an audit such as the one involving BRH and related entities. From: Barry J. Cohen [mato: Sent: Sunday, April 30, 2017 7:35 PM To: Thomas Turrin Cc: Jeffrey E.; Leon Black Subject: IRS Maybe there was an audit of an entity downstream from BRH. I only asked Apollo about BRH. How else would 2012 still be open? Sent from my iPhone On Apr 30, 2017, at 7:17 PM, Thomas Turrin < > wrote: This audit could have been done internally by IRS. I know that IRS sometimes does examinations internally (client isn't contacted until "internal" audit is concluded).. Because BRH Holdings LP is mainly a holding entity owning many other flow-through partnership entities, IRS could easily trace all K-1's flowing from these other partnerships to the BRH return without doing a field audit at Apollo's offices. It would not be difficult for them to undertake such an internal audit and trace all the K-1's into BRH. The IRS could readily pull this K-1 information from their system. It is very surprising to me that Deloitte nor anyone Apollo knew of these audits. Also, it's interesting that other non- founding executives at Apollo were also recently given assessment notices relating to audits of related Apollo partnerships. The IRS audit