From: To: "Barry Cohen" <I "Tom Turrin" Cc: "Jeffrey Epstein" <jeevacation®gmail.com>, "Leon Black" Subject: Re: IRS Date: Mon, 01 May 2017 00:51:25 +0000 Importance: Normal Tom, thank you for your more precise comments on my earlier note. Instructive and relevant. I know my basic questions for agent: I. Where did these adjustments emanate from? 2. Wasn't 2012 closed? 3. Have they been interacting with the designated tax partner at brh or anyone else at apollo? 4. Are we correct in assuming that this "assessment" moots their first inquiry since they appear to have answered their own initial question to leon? For apollo: I. Have other people been receiving brh assessments. 2. Do they foot with our (apollo's) records of brh ownership. For our working group: I. Once we understand where these adjustments came from, assess implications for other years, if any. I am sure there are other q's and we can all organize in the mom. It seems like we're all on the same page and you and jeffrey will touch bases in the morn as well. B Sent from my Verizon Wireless BlackBerry From: "Barry J. Cohen" < Date: Sun, 30 Apr 2017 23:35:28 +0000 To: Thomas Turrin Cc: jeffrey E<[email protected] Black Subject: IRS >; Leon 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 readil