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Title: |
Opinion Letter |
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Date: |
2001 |
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Preview shows 1KB of 4KB total |
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$32 |
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ID: |
#265722 |
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August 13, 2001
RAIT Investment Trust
1818 Market Street
Philadelphia, PA 19103
Ladies and Gentlemen:
We have acted as counsel to RAIT Investment Trust, a Maryland real
estate investment trust (the "Company"), in connection with the preparation of a
Form S-8 registration statement (the "Registration Statement"), filed with the
Securities and Exchange Commission, with respect to the offering and sale (the
"Offering") of up to 800,000 common shares of beneficial interest, par value
$0.01 per share of the Company (the "Common Shares"). You have requested our
opinion regarding certain U.S. federal income tax matters in connection with the
Offering.
In giving this opinion letter, we have examined the following:
1. The Company's Declaration of Trust, as duly filed with the State
Department of Assessments and Taxation of Maryland on August 14, 1997;
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