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We agree, except that you would need to look at the fair market value of the assets at the time of acquisition (which may or may not have been the same as the purchase price).

We agree.

1. We agree that the real property assets you describe are exempt under 802.2.(c) 2. The equipment you describe is not exempt under 801(b). Rule 802.1(b) requires that the acquisition be in the...

No new filing would be required, under the circumstances you describe.