REIT intends to own and lease, or lease and sublease, the “Properties”, which are located on inland lakes or coasts. The Properties contain boat slips, floating docks, storage facilities, boat servicing facilities, and support facilities such as laundry facilities and restaurants. One property also contains cabins that are made available to guests for one-week or shorter stays. The IRS holds that: 1) real estate assets for purposes of section 856(c)(4) and (5); 2) mounts received for racking structure space in dry dock storage facilities will not be considered as other than rents from real property; and. 3) presence of cabins at one of the properties will not cause the assets at that property other than the cabins and any areas reserved for cabin guests to be treated as lodging facilities within the meaning of section 856(d)(9)(D)(ii).