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12/21/90 - Advised (redacted) phone mail - 801.10(b) states that the value of assets to be acquired, i.e., assets of partnership, is fair market value of assets or, if determined and greater than the...

I concur, called 12/12/90

12/7/90 - Sounds OK, TFH

Called, 12-6-90, I concur, (see example 2 of 801.1(b)

None noted

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When a person acquires an income producing property from another person, it is reportable (given thresholds are met).Simultaneously acquiring a lease on the property is merely canceling the lease- not...

None noted

11/14/90 - Discussed with (redacted) made the clarification set out above.[note 1-D & Ewill have control, as defined by 801.1(b)]

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11/7/90 Discussed with J.M. Sipple. Advise our view is that sale of fee interest in realproperty, from which lease payments are derived as a result of building on such property, isexempt under 802.1(b...

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11/2/90 Called (redacted) advised that foreign company must use its regularly preparedfinancials, if prepared within 15 months of filing or acquisition, to determine its size. Itcannot revise such...

None noted

None noted

See below

[note 1-Continuum theory - not reportable - if [redacted] shares are not sold then theyshould file for them]-[note 2-continuum theory applies]-[note 3-802.63 lease Financing]

Called on 11-26-90. Agreed that a new filing is not required. PNO has taken the positionover the last year or so that a new filing is not required if a person files to acquire all of acompanys assets...