0507006 Informal Interpretation

From: (redacted)
Sent: Thursday, July 14, 2005 5:14 PM
To: Verne, B. Michael
Subject: Question about 802.5

Mike:

I have a clientthat owns self-storage facilities. Customers can rent them on a month-to-monthbasis to store possessions. It seems that 802.5 (in connection with 802.4)would exempt the acquisition of the securities of the company that owns andoperates the storage facilities. They meet the 802.5 test of "investmentrental property" -- they're rented to third parties; for tax purposes, therental is considered a lease; they are held for rental purposes.

I wasn't able tofind any informal opinions regarding self-storage facilities, so I thought Iwould ask if you've dealt with this before.