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Technology Stocks : Lucent Technologies (LU)
LU 2.690+1.9%3:59 PM EST
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To: Tech Bull who wrote (16505)10/8/2000 11:47:44 PM
From: David C. Burns  Read Replies (1) of 21876
 
Security: Lucent (OK)
New Company: Avaya (very strange this isn't a pull-down from your securities list)
New shares per old: 0.0833333 (too bad it won't take 1/12)
Cost per old share: ???
Cost per new share: ???

From the Avaya Inc. prospectus:

Lucent has received a ruling from the Internal Revenue Service, or the IRS, to the effect that the distribution will qualify as a tax-free transaction under Sections 355 and 368(a)(1)(D) of the Internal Revenue Code, or the Code. The ruling provides that for U.S. Federal income tax purposes:

[first two bullets omitted]

. the basis of the Lucent common stock and our common stock in the hands of Lucent's shareowners immediately after the distribution will be the same as the basis of the Lucent common stock immediately before the distribution, allocated between the common stock of Lucent and us in proportion to their relative fair market values on the date of the distribution;

. the holding period of our common stock received by Lucent shareowners will include the holding period of their Lucent common stock, provided that such Lucent common stock is held as a capital asset on the date of the distribution; and

[last bullet omitted]
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