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OK - NO Partnership STAFF COMMENT: Not the test under 802.20 STAFF COMMENT: Seems to be all part of formation PMN Office, not Commission, also below in ref. to FTC

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Pursuant to the 802.1 ordinary course of business exemption for realty the acquisition of proven gas reserves that hasn't begun to produce revenue is exempt.

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[note 1-PMN Office]

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OK

You do not deduct costs (including subcontracted work) from gross revenues (turnover) in order to derive a figure comparable to net sales. Net sales are gross sales minus returns and allowances -not...

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Called (redacted) and informed him that this is exempt under C-10 - This is exempt under C-10 See #38 new Premerger Practice Manual. JS concurs. Superimposing a holding company over an operating co...

Called on 7/24/91- Informed the inquirer that we would treat (redacted) as the State or agency of the state of (redacted) since it is an instrumentality of the state, formed by the state for the...

This appears to be ok. It is merely a name change - the form (SIC info) remains the same for the antitrust analysis. PS: RS concurs called (redacted) 7-12-91 and left message

7/2/91-Called (redacted) and advised that, in our view, an officer or director who takes stock in the company which employs him cannot avail himself of 802.9 if the stock value held will exceed $15 MM...

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Called on 7/18 - Confirmed (redacted) advice given.