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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...
10/11/95 - 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...