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6/18/92 Advised (redacted) that his letter accurately reflects the present view of the PMN Office regarding real estate purchases by REITs governed by the applicable IRS regulations.

6/8/92 - called (redacted) and advised that, based on the fact scenario outlined above, B would not control X through the holding of voting stock but rather pursuant to a stockholders' agreement...

Grant of an exclusive license for a specific product use and limited in time and geographic scope is the transfer of an asset and subject to the HSR Act. Product, time and geographic limitations go to...

When assets being acquired constitute an entire entity, division or operating business, Items 5(a), 5(b)(i) and 5(b)(iii) should be completed assuming such data is transferred to the acquiring person...

Debt securities are not assets

Acquisition of less than 100% of partnership interests is not reportable event. The .5%which remains outstanding was created when the partnership was originally formed and then sold to a 3rd person to...

Accurately reflects advice given. Also, (redacted) servicing rights are not considered c(2) assets. Therefore, another exemption is necessary if filing is not to be required when servicing rights are...

5/14/92 - called (redacted) and advised that the letter set forth a proper use of7A(c)(1) and, based on the facts in the letter, no filing would be required.

called (redacted) 5-11-92. I concur with letter.

Where is annual report with note restating net sales and total assets (See ABA # 158)? Unless you can convince us otherwise, the PMNO is not convinced that the net sales are separable from the...

C is not acquiring 50% of B and B does not meet the size of 802.20.

Class A Common

When a partnership is formed, no reporting is required where money is distributed to a partner who has contributed other assets as long as the distribution is proportional to the relative partnership...

If sale has been ordered, approved & supervised by RTC then it is exempt as a transfer from a govt. agency. Sale may be from a subsidiary of its assets.

B