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To: the dodger who wrote (28981)	7/27/2000 9:04:51 AM
From: Mike Buckley	Respond to of 54805

Dodger, You refuse to let a guy some sleep! :) 1. Are there any tax consequences to the future QCOM/Spinco transaction? It is being reported and published on the company's web site as a "tax-free distribution." In the Wall Street Radio interview Jacobs said this aspect of the spin-off has been in the hands of the IRS for months. Though they have not yet had the official ruling by the IRS, everything has gone smoothly so far and they expect it soon. 2. Is there a rule on this? ... my memory is starting to fail me Fortunately, this is one issue in which I have no memory problem. Instead, it's total ignorance. 3. Any idea where might I find "the rule" Yes. It's a simple document I'm surprised you don't have on your night stand for your bed-time reading considering that you get to sleep all you want. It's called the United States Tax Code. :) --Mike Buckley

To: the dodger who wrote (28981)	7/27/2000 9:28:24 AM
From: Pawhuska49	Read Replies (1) \| Respond to of 54805

Actually, it's called the Internal Revenue Code "Code" is used here for obvious reasons. "Internal" Revenue also misleading, but not as bad as the British counterpart "Inland Revenue," which gives people on the coast the impression they're not taxable. As for locations of the rule in our Code, I haven't got a single copy at home, but try looking at Section 351 et seq. for tax-free organizations, reorganizations. If memory serves, Section 354 would bear the most fruit here. Good luck understanding it. I never did. Cheers, Mike