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As long as it is raw land. Land that formerly and currently has no business operating on it . I concur [note 1-I find this vague. Does this mean there may be commercial property. Note: Phone call to...

OK 7/29/88

OK - 7/28/88

Letter is incorrect. For 801.40(c) the full face value of financing is included. It is not intended for 801.11(e) where it is taken down after the acquisition. Writer was informed on 7/28/88

Notified the writer that facts were insufficient to determine reportability particularly reformation of (redacted) and acquisition by A of preferred (voting?) Shares of (redacted) 7/28/88

OK - 7/25/88

Ok - 7/18/88

OK Limited strictly to situations like this one in which the different issuers are identical in actual operation. 7/18/88

None noted

None noted

None noted

OK - 6/6/88

The commissions are an expense, as indicated on the income statement and are not deducted. The total revenues are counted for purposes of determining revenues under 802.20(b).

Called author on June 2. Letter reflects the substance of our earlier conversation concerning these unique facts and the application of 802.51(b)(1)

None noted

OK 6-23-88