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3/26/98 Advised writer that Rule 802.1(c) is applicable to the purchase of used airplanes and the transaction is exempt under that rule. However, we do not think that the technical requirements of 802...

we now say it is a v/s if the management board members are coming from outside the membership interest holders. If coming from inside then it is more like a partnership -[note 1-I concurred as of 3/26...

3/18/1998, called writer to inform him that size of person test (by JV) was [not] met because the sub-leasing is not a guaranty and, thus, would not be included as a contribution in the formation of...

3/18/98 Writer confirmed that on chart included on Section 4 Page 2, the husband and wife noted held all of the outstanding voting stock of the nine corporations listed. The balance of the authorized...

3/18/98 Advised writer that sale of subject assets did not appear to constitute the disposition of an “operating unit”. Since seller was remaining in the mortgage servicing business, the transaction...

Agree 3/16/98

Called (redacted) 3/13/98. Does not meet the size-of- transaction test. I concur with this letter

called 3/13/98 I concur with this letter

3/12/98 Confirmed w/ writer that same procedure should be followed, namely that(redacted) does not have to file, but filing may be made by (redacted) and (redacted).