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See revision of this transaction outlined in letter dated 6/9/87-[note 1-5 pages of exhibit A, B and C]

On 6/3/87 I notified (redacted) that I did not know enough to dispute his conclusions but that this does not bind either agency in any future transaction. He will send in a letter to confirm that...

I told him that (redacted) is a corporation engaged in commerce through its subsidiaries (redacted) and it must report

06-11-This is correct

Since not non-income producing - still exempt

See notes of (redacted) in reply to this letter on last page-Called (redacted) on 6/19. Told him we would accept filing from C for subsequent sale of A’s assets even though at time of filing it does...

Told him that beneficial interest in the assets must pass for the acquisition to close in escrow. Title and consideration arent being passed. We dont like the idea of claiming it is not closed for the...

We do not write response information letter so notified writer- directed him to F.I. of 5/29/87 .

Each partnership is its own UPE. The alternative test for control in 801.1(b)(2) does not apply to partnerships. (See FR at 20062, 5/29/87). Re: Last paragraph if A controlled the partnerships, an...