REIT Opinion

REIT Opinion. An opinion concluding that commencing with the Company's initial taxable year ended December 31, 2020, the Company has been organized and has operated in conformity with the requirements for qualification and taxation as a REIT under the Code, and its actual method of operation through the date thereof has enabled, and its proposed method of operation will enable, the Company to meet the requirements for qualification and taxation as a REIT under the Code