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6/21/99 Since acquiring person paying no consideration, transaction reportable under ABA # 139 only if it is assuming more than $15 MM in liabilities. Cash payment referred to in last sentence on pg...

6/17/99 TS (co-counsel with writer) advises that none of B’s shareholders are U.S. persons and, thus, their respective minority takings of A’s stock would be exempt under 802.51(b). As to...