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Re: None

Wednesday, 11/03/2021 9:14:20 AM

Wednesday, November 03, 2021 9:14:20 AM

Post# of 749756
~ The Recent (PLR) "Private Letter Ruling" Has ZERO' To Do With, the "wmi-lt", WMIH, "COOP" or Anything Else of "Our" Concern', This Is WMIH "COOP" BOD's Concern, and has also already been SEC Filing Reported' ~

... I surely hope that no one is hanging their hat on those' sloppy and incomplete assumptions' ... ? ...

I've posted this before, ... a thorough review of that recent PLR, concludes that this PLR is referencing the closing of WMMRC' ... and DOES NOT have anything to do with the "wmi-lt" ...

This recent', PLR Has ZERO To Do With, the "wmi-lt", the WMI Reorganized, "Holding Company", WMIH "COOP", or, the DTC issued ESC Cusips ...

And, As Also SEC Filing Reported, ... This PLR is referencing the Closing of WMMRC', ... WMI's PMI Insurance Provider' ...

https://www.irs.gov/pub/irs-wd/202044002.pdf

"Based on the information submitted and the representations made, we conclude that the conditions of Rev. Proc. 94-45 have been satisfied. Accordingly, based on the representations made and the information submitted, we rule that Trust is classified for federal tax purposes as a liquidating trust under § 301.7701-4(d) and the extension of Trust’s term to Date 7 will not adversely affect that determination"

Now, A Simple reading and an actual review of the "Conclusion" referenced, Rev. Rule. 94-95, provides the true reference to the closing of WMI's PMI Insurance Provider, WMMRC' ...

Rev. Rul. 94-45

Insurance companies; transfer to corporation controlled by transferor. An assumption reinsurance transaction that is used to effectuate a transfer of insurance and annuity contracts as part of a section 351 exchange is not subject to the provision of sections 803 and 805 of the Code, and sections 1.817-4(d) and 1.848-2 of the regulations. Rev. Rul. 75-382 revoked.

===========================

turn the page', ... Come On Already, ... this, sloppy research', was just another irrelevant, and misrepresented' rabbit hole' ... reminds me of "aya", etc, ...

just sayin'

AZ

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