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We have deabted the REIT status issue a lot ofthis message board as past post will explain. IN anutshell as I understand.*As the letter of the lawgoes the structure fits in the rules of incometest(only 75% of the income to a REIT need be pure lease),asset tests, etc. to quailfy as a REIT.*PZNs/H's only owns less then 10% of CCA private opco. Thusnot legal control.*This structure as many ofpresent day REIT's, with their private service Corps.,could be under the IRS fire anytime.