I'm back - without a tan; guess you win that one. But you're off track re Flip/r7 dialog on taxes. r7 popped up here claiming Treasury was going to disallow PZN's REIT status - and never responded with anything of substance when questioned about his info.
The analysts who worried about taxes also worried about OPCO. IMHO (which, trust me, you ought to trust on this), you can worry about one but not the other. The REIT tests are mechanically met. But you say that the ties between mgmt can be "construed" as effective control. I might agree, except for the lawsuit, which solved all the problems, right?
P.S. I wouldn't trust Litt about tax matters any more than I'd trust him about REITs. He's been calling them pretty poorly in the past year.