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Called (redacted) 1-30-92. The first and second steps are exempt under c-3 and c-10. The last step (3rd) is reportable for both shareholders for the conversion. JS & RS concur.

12/26/91- called (redacted). Advised that Scenario A is reportable. (Do not trace partnership interest held thru to assets of partnership.) B is not reportable. C isreportable if, after redemption of...

12/19/91 (Redacted) advises that the (redacted) are built by a German firm. (Redacted) purchases them and arranges leases with persons needing equipment. Lessee uses this approach rather than...

12/18/91 advised (redacted) that contents of this letter did not reflect the presentview of the PMN Office. If land had produced a stream of income (which itapparently had) and size tests were met...

Dec. 12: Called (redacted). Reportable as it stands now. 801.40(c) requires aggregation of all contributions to J.V. R.S. of our office agrees.

12/9/91 called (redacted). Advised that Tom and I were of the view that even though the Medical Group, the Hospital Corporation and the (redacted) had the same equity and interest holders, no one...

12/3/91 called (redacted) and advised that where a state Commissioner of Insurance, an elected state official, becomes the receiver or conservator of aninsurance company pursuant to a state statute...

Section 802.50(a)(2) requires a person to as certain the amount of sales in or in to the U.S. attributable to the foreign assets. A person may rely on financial records even though they are not...

Title is not passing. Acquiring only right to receive income stream.

None (but see file # 9112007)

Title (and other indicia of beneficial ownership) will remain w/ trust. Only cash equivalent (right to receive income stream) is being purchased. Payment for such is excluded from size-of-transaction...

11-25 Called (redacted). OK.

Contacted (redacted) 11-22-91 and said I disagree. PS. RS concurs with me. The Unit holder must report. See # 69 Premerger Practice Manual.

11/19/91 - called (redacted). Advised that since sale involved less than all of (redacted)'s rights in bona fide financing arrangements (and buyer does not engagein commercial trucking activities...