From: Thomas Turrin Sent: Sunday, April 30, 2017 11:18 PM To: jeffrey E.; Barry Cohen; • Cc: Leon Black Subject: RE: Re: 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 was more than just BRH. The BRH Holdings LP adjustment of income is likely to have resulted from an audit of one or more of the investee entities owned by BRH. From: jeffrey E. [mailto:[email protected] Sent: Sunday, April 30, 2017 6:51 PM To: Barry Cohen; Thomas Turrin; Cc: Leon Black Subject: Re: We were told that neither Deloitte or apollo tax knew of this . That was the first question On Sun, Apr 30, 2017 at 6:18 PM Thomas Turrin < vrote: Please see my comments below in red. EFTA_R1_01892823 EFTA02651276