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OK as amended W. Kaplan 5/21/86

O.K. W.E. Kap

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On 5/29/ I informed (redacted) that the Transaction was not required to be filedsince (1) If it involves voting securities it is exempt under 802.30 as an intra-person transaction. If it is not voting...

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I concur with this letter except that we cannot sign and return a copy of your letter P.S. called (redacted) 1:30 P.M. May 1, 1986. The PMN Staff concurs with your letter, except for exception as...

I did not advise the writer that the acquisition of A by B was non reportable if there was an assumption of A’s liabilities by B. The transaction would be non reportable only if the sale consideration...

4/7/86 Called Mr. (redacted) and indicated that the PMN staff was in agreement with the facts as stated. However, did point out to Mr. (redacted) that a reference to no regularly prepared balance...

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called 4-16-86 upon later review this letter is inaccurate. All intraperson transfers must be shown as item 5 revenues

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It is OK to use this form up until 5-23-86. After this date the PMN Office will only accept 1982 as the base year.

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