Question
(redacted)
May 7, 1987
Andrew Scanlon
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
6th & Pennsylvania Avenue, NW
Room 303
Washington, D.C. 20580
Dear Mr. Scanlon:
This letter is to confirm matters we discussed in our telephone conversation on May 7, 1987 concerning the Hart-Scott-Rodino Premerger Notification Form. I asked you whether a partnership 99% owned by an individual and 1% owned by an irrevocable trust in favor of the individuals children would be deemed controlled by the individual. You stated that the partnership would not be deemed to be controlled by the individual. Thus, revenues of the partnership would not be attributed to the individual. I also asked you if revenues from passive investments in stocks, certificates of deposits, money market funds, etc., would be reportable. You stated that they would not be reportable because the revenues must be derived from the reporting persons operations in various industries.
I would appreciate your written confirmation of the accuracy of the foregoing discussion by your return of this letter with your signature at the bottom of the next page. It is my understanding you will respond in approximately two (2) days after receiving this letter. If possible, please respond by Federal Express and bill to our account number (redacted).
Thank you very much for your cooperation. I have found you to be most informative in matters concerning reporting under the Hart-Scott-Rodino Act.
Very truly yours,
(Redacted)
_____________
Mr. Andrew Scanlon
Premerger Notification Specialist
Federal Trade Commission
cc:(redacted)
(redacted)