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Title: |
Opinion Letter |
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Entities: |
RAIT Investment Trust; RAIT Partnership, LP; Ledgewood Law Firm; RAIT General, Inc. |
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Date: |
2002 |
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Size: |
Preview shows 2KB of 9KB total |
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Price: |
$41 |
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ID: |
#265688 |
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[LEDGEWOOD LAW FIRM LETTERHEAD]
March 13, 2002
RAIT Investment Trust
1818 Market Street - 28th Floor
Philadelphia, PA 19103
RAIT Investment Trust
Qualification as
Real Estate Investment Trust
Ladies and Gentlemen:
We have acted as counsel to RAIT Investment Trust, a Maryland real
estate investment trust (the "Company") in connection with the offer and sale by
the Company of 1,200,000 common shares of beneficial interest (the "Shares"),
par value $.01 per share (the "Common Shares"), as set forth in the Company's
Registration Statement, as amended, Registration No. 333-69422 (the
"Registration Statement"), the prospectus dated November 2, 2001 included as a
part of the Registration Statement (the "Base Prospectus") and the Company's
Prospectus Supplement dated March 8, 2002 (the "Prospectus Supplement," and
together with the Base Prospectus, the "Prospectus"). You have requested our
opinion regarding certain U.S. federal income tax matters.
The Company conducts its operations through RAIT Partnership, L.P., a
Delaware limited partnership (the "Operating Partnership"), which owns
substantially all of the Company's assets. The sole general partner of the
Operating Partnership is RAIT General, Inc. (the "General Partner"), and the
sole limited partner of the Operating Partnership is RAIT Limited, Inc. (the
"Limited Partner"). The Company owns all of the stock of each of those
corporations. As of September 30, 2001, the Operating Partnership had interests
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