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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...

I concur PS-called 8-12-91

I concur PS-called 8-12-91

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...

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

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Pursuant to the 802.1 ordinary course of business exemption for realty the acquisition of proven gas reserves that hasn't begun to produce revenue is exempt.

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[note 1-PMN Office]

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None noted