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Comment: The initial transaction is exempt (32% of v/s) under Section 802.20. The option is reported if and when it is exercised. Although it is one part ofBeneficial ownership, that is the right to...

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I concur per phone call 11/25/86 Upon later review it appears that this is an incorrect interpretation. This appears to be an acquisition of a home builder company and not an acquisition of an exempt...

Upon later review it appears that the facts are incomplete. Although subleases may not involve acquisitions of assets, a lease acquisition may be an asset acquisition where the landlord releases the...

Reviewed 3/10/87 LAH Incorrect that Ptp has no assets until makes acquisition. total assets (assuming no bal. sheet) include all assets held at acq’n, less cash used as consideration & v/s of target.

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OK WEK Upon later review on 3/9/87

Upon later review this letter appears to be correct 3/9/87 W.E.K.

Ok upon later review by WEK 3/9/87

Upon later review it appears that the voting securities acquisition is exempt under 802.20 as indicated, and, though there is a contract to appoint the majority of the board, entering into such a...

OK upon later review by WEK 3/9/87

OK upon review by W.E.K. 3/9/87

OK upon later review on 3/9/87 W.E. K.

OK upon later review on 3/9/87 W.E.K.

OK upon later review. 3/9/87. W.E.K.

No note was made on this letter at the time it was reviewed. Upon later review itappears that no special treatment can be given to any transaction or transactions merely because of asserted lack of...

The issue of which entities within a religious organization engaged in businessactivities must file is still being considered. Advice is given in each situation basedupon the individual facts of that...