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10/1/90 Told (redacted) that the first mode of analysis is correct but not the second andassuming the faith stated the conclusion is correct. TFH

9/24/90 Called him back. Clarified that since the size-of-person test isnt met there is noneed to go to the exemption under 802.1 for realty. Its really a 2-step process: 1) do youhave to file under...

Advised that 801.1(c)(2) requires insurance company to include assets held in a separateaccount for size of person test. - JDahnke 9/20/90

9/18/90 Advised (redacted) that pursuant to Rule 801.11, the size of person test includesthe acquired person plus all entities it controls. He agreed and stated that the acquiredperson controls no one...

For purposes of the size-of person test for an individual, include the financials of all entitiescontrolled plus any other investment assets. Exclude personal assets such as a house or car. Include...

Sale - leaseback in ordinary course

I never received a letter dated 9-4-90But did have phone conversation

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B controls A because B has the power to designate directors of A.

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