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2/21/95- Called writer and advised that I was in agreement with the conclusion reached inhis letter.

This letter supersedes a letter from (redacted) dated 2/17/95 - This letter is non responsive to a FOIA request (95-0099) dated 2-9-95-Based on my understanding of the facts LLC-1 is exempt under §802...

2/13/95-Called the writer and told her that we regard the transfer of the hospital from A toNewco as part of the formation of a non-profit joint venture and thus exempt, rather than are portable...

I concur. P.S. Called 2/10/95RS concurs - He did not review the letter but concurred based on my oral presentation of the facts

2/7/95-Writer advises that loans to LLC are being made at about an 8.5% interest rate,which is a commercially reasonable rate. Advised that if note were below acommercially reasonablerate, the...

2/3- OK, if the below $10MM balance sheet is prepared in accordance with the same principles used for prior monthly balance sheets.