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Called, 12-6-90, I concur, (see example 2 of 801.1(b)

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When a person acquires an income producing property from another person, it is reportable (given thresholds are met).Simultaneously acquiring a lease on the property is merely canceling the lease- not...

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11/14/90 - Discussed with (redacted) made the clarification set out above.[note 1-D & Ewill have control, as defined by 801.1(b)]

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11/7/90 Discussed with J.M. Sipple. Advise our view is that sale of fee interest in realproperty, from which lease payments are derived as a result of building on such property, isexempt under 802.1(b...

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11/2/90 Called (redacted) advised that foreign company must use its regularly preparedfinancials, if prepared within 15 months of filing or acquisition, to determine its size. Itcannot revise such...

Lessor - title, security interest. Lessee - possession, risk of loss due to damage or use of the leased assets arising from lease. Right to require sale to third party . Right to acquire for greater...

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[note 1-Continuum theory - not reportable - if [redacted] shares are not sold then theyshould file for them]-[note 2-continuum theory applies]-[note 3-802.63 lease Financing]

Called on 11-26-90. Agreed that a new filing is not required. PNO has taken the positionover the last year or so that a new filing is not required if a person files to acquire all of acompanys assets...

Called 11-28-90- I concur [note 1-Premerger view, not FTC]

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