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This cannot be exempt under 802.1 or the c-2 exemption because substantially all of the assets of the acquired entity will be acquired. As a result, a “business†will be acquired. Thus, this cannot be...
Checked with (redacted) - 10/7 called (redacted) advised that letter is ok 801.90(avoidance devise) is always an issue and we will continue to monitor. We are also aware of partnership formation...
10/21-Called and advised (redacted) that it is a Premerger Office position (and not that of the Commission) regarding filing or non-filings for apartment bldgs.