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9/13/91-Advised (redacted) that letter had been reviewed by PMN staff and it was in agreement that Company Bs agreement with X did not pass beneficial ownership of the 13% of As voting stock to B...

9-12-91 Called-If the assets previously filed for are the same and the only assets of the partnership then no new filling needed. If partnership has other assets not previously filed for then a new...

09/06/91-agree w/ the conclusion herein

None noted

None noted

None noted

None noted

On 8/21/91-I advised (redacted) that her 8/21 letter to me was troublesome to the PMN Office. The continuum theory is based upon there being a contract betweenA and B and, for whatever reason, the...

Called (redacted) 8/20/91-I concur with this letter after confirming that the REIT is subject to IRS tax limitations

8/13/91-John Sipple says no filing required but questions raised are somewhatdifficult. However, since Bank A is not selling all, or substantially all, of its creditcard accounts in a given geographic...

8/12/91-Advised (redacted) that formation of a bona fide partnership is not negotiable under 801.40. Viewing this as a purchase of an interest in non-productive real estate, the transaction is also...

I concur PS-called 8-12-91

I concur PS-called 8-12-91

OK-08/09/91 JK

8/9/91 called (redacted) Advised that in no case can 45 day period be earlier thanday before option signal. Would also suggest that 45 day calculation be used foreach day of the 10 days within which...

OK - NO Partnership STAFF COMMENT: Not the test under 802.20 STAFF COMMENT: Seems to be all part of formation PMN Office, not Commission, also below in ref. to FTC