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The size-of-person test is based on the last regularly prepared balance sheet if not over 15 months old. Facts of letter indicate that size tests are not met.
5/1/96- Advised writer that U.S. issuers right (even though non-exclusive) to useforeign government (redacted), a (redacted) which transports (redacted) after it passesthrough the (redacted) of a...
Based on all of the facts, you have made the determination that it is not reportable. (Assuming the size-of-person test is met). I concur that this transaction is exempt by (redacted) under Section...
4/26/96 Advised co-counsel to writer that cash held by A, regardless of its source, is an exempt asset. However, assets of A used to manage properties of others are not exempt under 802.5(b)(iv) and...