From: Barry J. Cohen < Sent: Sunday, April 30, 2017 11:35 PM To: Thomas Turrin Cc: Jeffrey E., ..c.. .> L ; Leon Black Subject: IRS Maybe there was an audit of an entity downstream from BRH. I only aske= Apollo about BRH. How else would 2012 still be open? Sent from my iPhone On Apr 30, 2017, at 7:17 PM, Thomas Turrin <[email protected] <mailto:TTurrin@re=-co.com» wrote: This audit could have bee= 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 h=lding entity owning many other flow-through partnership entities, IRS coul= 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 =nformation from their system. <=p> It is very surprising to =e that Deloitte nor anyone Apollo knew of these audits. Also, =t's interesting that other non-founding executives at Apollo were also recently given asses=ment notices relating to audits of related Apollo partnerships. &nbs=;The IRS audit was more than just BRH. The BRH Holdings LP adjus=ment of income is likely to have resulted from an audit of one or more of =he investee entities owned by BRH. <=p> <=p> From: jeffrey =. (mailto:[email protected]</=>J Sent: Sunday, April 30, 2017 6:51 PM To: Barry Cohen; Thomas Turrin; <mailto Cc: Leon Black Subject: Re: We were told that neither Deloitte or apollo tax kne= of this . That was the first question EFTA_R1_01892858 EFTA02651285