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…diligently reviewed the history and factual circumstances with their accountants and other tax advisors. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the Foreign Entities. including the Non-ApelleWREI Controlled Entitle; for 2011, which the Taxpayers are now doing via the filing of Form 1040X today. The Taxpayers are neither accountants nor lawyers, and because the Taxpayers' ownership arrangements related to the Partnership and other…