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I disagree with the PMN Office approach in #268. (AS concurs). Have advisedto file as one transaction because of nexus with the U.S., 802.50 does not apply tothe second part. Called (redacted) 10-25...

110/23 Spoke to writer: Exemptions are limited to officers and directors but can include employees of either side.

10/14/95 - Advised co-author that letter reflects position of Premerger Office concerning realty purchases by REITs which have not yet qualified with IRS. Noted that should REIT fail to qualify the...

10/13/95 - Advised writer that it is the view of the PMN Office that the transaction described would be exempt under 802.10. Letter 236 in 1991 ABA book notes that creation of a new shell holding...

10/13/95 - Advised writer’s phone mail that letter was correct in its statement of how the PMN Office presently views formation of LLC’s. RBSmith

10/11/95 - Advised writer that filing as an 801.40 formation was inappropriate in this fact setting. While Company A is being merged in a sub of Newco Company B remains inexistence as a contributor to...

10/5/95. Called writer. He confirmed that none of the listed entities controlled any other entities. Fair market value of Partnership assets is not book value and has been determined without...