<table><tr><th>From:</th><th>Okun, Brad R</th></tr><tr><td>Sent:</td><td>Tuesday, December 27, 2016 2:25 PM</td></tr><tr><td>To:</td><td>Jeffrey E.</td></tr><tr><td>Subject:</td><td>RE:</td></tr></table>

I don't think we can argue that the 8865s filed by Apollo provided all the p&I for the pships, since as a category 2 filer they were only required to provide info as to their share. If all shares were pro rata, the IRS could extrapolate, but I don't believe anything in the information returns makes that clear. I am confirming with Apollo.

Brad R. Okun I Partner

Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue of the Americas I New York, NY 10019-6064
(212)
www

From: Jeffrey E. [mailto:jeevacation@gmail.com]
Sent: Tuesday, December 27, 2016 9:22 AM
To: Okun, Brad R
Subject:

further thoughts/?

please note

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