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I informed the writer that the burden is on the acquiring person to determine the fair market value of the assets being acquired separately from each of the 12 persons and the unallocated value of the...

OK - Limited to the facts. 8/5/88

OK-8/4/88-Limited to the facts.

I concur with this letter - also reviewed by (redacted) - Attempted to call three times noanswer last call 8-18-88

Talked to (redacted) 8/18 confirmed that these were both asset transactions; advised that if fair market value or, if higher, the acquisition price, is $15MM or less for assets of each entity, then...

None noted

I have no expertise in matters concerning the Internal Revenue code. In order to determine reportability under H-S-R concerning the acquisition of partnership interests you look to the acquiring...

Acquiring side board of directors should determine fair market value to make sure price is below $15 mm

Acquiring side board directors should determine fair market value to make sure price is below $15mm [note -same letter as 8808008]

As long as it is raw land. Land that formerly and currently has no business operating on it . I concur [note 1-I find this vague. Does this mean there may be commercial property. Note: Phone call to...

OK 7/29/88

OK - 7/28/88

Letter is incorrect. For 801.40(c) the full face value of financing is included. It is not intended for 801.11(e) where it is taken down after the acquisition. Writer was informed on 7/28/88

Notified the writer that facts were insufficient to determine reportability particularly reformation of (redacted) and acquisition by A of preferred (voting?) Shares of (redacted) 7/28/88

OK - 7/25/88

Ok - 7/18/88

OK Limited strictly to situations like this one in which the different issuers are identical in actual operation. 7/18/88

None noted