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I called (redacted) and explained to him that, with respect to the first paragraph of his letter, non-income producing property is generally exempt, regardless of the nature of the acquiring person...

None noted

Acquiring person will purchase 5% then corporation A will redeem all of its outstanding stock-leaving B-in control. If B is instrumental in A redeeming all of its share, transaction is reportable. See...

None

802.30 Where various subsidiaries are held by ownership of voting securities the transfer of (redacted) the subsidiary (second tier) directly to parent so that parent will hold second tier subsidiary...

4/12/93 – Advised writer that the 7A(c)(1) exemption was available to the proposed REIT due to its 1) having obtained a tax opinion that manner in which company intends to operate is in compliance...

Called [redacted] 4-6-93. Two filing fees are required for this transaction. RS concurs.

In the formation of a partnership the acquisition of partnership interests in return for assets or voting stock is not reportable since a partnership interest is deemed to be neither a voting security...

None noted

[note 1-enclosure is a second letter]-[note 2-4/28 - as long as delay is related to continued testing.]

3/24/93 called [redacted]. Advised that PMN Office treated the 1989 filing as constituting the taking of beneficial ownership of the assets of the acquired person once the waiting period was observed...

3/24/93 called [redacted] and advised that [redacted] qualifies as a state agency and is therefore not an entity within the definition set forth in 801.1(a)(2). Therefore, its purchase of the...

3/23/93 - advised [redacted] that, based on this fact scenario, in which the very same assets were to be purchased from (potentially) two or more acquired persons, 801.11(e) could be used to reduce...