<table><tr><th>From:</th><th>Barry J. Cohen</th></tr><tr><td>Sent:
To:</td><td>Wednesday, September 20, 2017 8:43 PM
Jeffrey E.</td></tr><tr><td>Cc:</td><td>Melanie Spinella (Spinella@ApolloLP.com); Brad Wechsler</td></tr><tr><td>Subject:</td><td>Re: EY audit experience</td></tr></table>

Yes. We have all of their comments. I hope to circulate shortly. =

Sent from my iPhone

On Sep 20, 2017, at 3:54 PM, jeffrey E. <jeevacation@gmail.com <mailto:jeevacation@g=ail.com» wrote:

very talented , question. has any=of them thoroughly reviewed the draft return ,

On Wed, Sep 20, 2017 at 3:38 PM, Barry J. Cohen =span dir="ltr":  <c.=om
m> > wrote:

Here is the summary we have on audit experience of o=r EY team.

John Cook —= Partner PCS

*

• Significant number of Federal=compliance audits (line by line)

• Federal audits on:<=u>

	" At-Risk Limitations & basis

		- Schedule Cs

	• Charitable contribution a=d investment interest expense tracing

	- Gift tax audits

- Significant number of NYS and CT &=8211; Statutory residency, domicile and income allocation

audits=/u>

</=pan>

David Kirk=; Partner — National Tax PCS

- About 50% of the a=bits are Global High Wealth

* Most of the matters involve=treatment of pass-through items on the 1040s – passive loss, at-risk= interest tracing and SE tax

</=pan>

Elda Di Re=; Partner — National Tax PCS

*

• S Gift Tax Audits=/u>

- 6 Federal compliance audits (audit of each line of return)=u>

- Dozens of regular 1040 audits

</=pan>

Greg Rosica R=1; Partner Tax

Significant experience=representing clients in Federal and state (NY, NJ, CT, GA, CA) audits incl=ding:

- Complex financial tr=nsactions (distressed debt, related party transactions) involving individu=ls and their pass through entities

- Audits of passive v =ctive status

- Support for business=use of assets (real estate, airplanes, yachts, art, equestrian)<=u>

- Investment v trade o= business classification (cap gain v ordinary, developer v investor)

- Equity v debt treatm=nt in real estate transactions

</=pan>

Mitchell Kops &#=211; Principal — National ITS

Some audit experience =t Withers including:

- Private plane

- Foreign Tax credit/deduction matter

</=pan>

Joseph Fuschetto=— Executive Director — PCS

• Federal =udits of Schedule Cs

- Federal Audits of Schedule Ec; passive v active, at-risk

- Multiple gift tax audits=/u>

- NYS residency and income allocation audits=/li>

</=pan>

Surya Shivakumar &#=211; Senior Manager — PCS

Barry J. Cohen =|
Elysium Management,=LLC |

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