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I spoke with the author of the fax today, (redacted) 1/11. I told him that so long as the realty underlying the (redacted) was the only asset being transferred, the transaction is nonreportable.

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12/20 - Spoke to writer; told him as above; X & Y have to file. HDR

12/20/95-Advised writer that lessee's taking of title (or security interest) in facility would not constitute the transfer of beneficial ownership of the faculty and thus, no HSR report would be...