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I advised (redacted) that the two transactions described are exempt- but are exempt under c(1) rather than c(2). I explained that exemption under c(2) might lead to the conclusion that all accounts...

Left message with message center that I agree with above.

I advised him that 802.63 was not broad enough to include the transaction

Exempt re not meet the size of transaction test.

okay, assuming acquiring person is U.S. UPE

None noted

I advised (redacted) that the word property used in the last sentence of the second complete paragraph of P. 2 was inaccurate and that all property did not qualify. Cash only passed through the newly...

Must file. Selling all of the business in a state selling of operating division

None noted

:Parties advised (by Wayne Kaplan) 1/30/87 that letter contained insufficient info. for us to make a determination.

Called on 1/16/87 confirmed his understanding set forth in paragraphs 3 and 4 on pp. 2 and 3

1/14/87 Called (redacted) not available left message with (redacted) that the 30 day waiting period not the 15 day period would apply to this transaction since the consummation includes other than...