Common use of Significant Assumptions Clause in Contracts

Significant Assumptions. Our opinion is expressly based upon any assumption set forth herein and as follows: 1. Beginning with the Company’s REIT election for the taxable year beginning January 1, 1987 and ending with the Company’s taxable year ending December 31, 2004, the Company met the requirements for qualification as a REIT and was taxed as such. 2. Each Subsidiary Partnership was properly classified as a partnership for federal income tax purposes at all times prior to January 1, 2005. 3. The facts and representations as made by Xxxxx Xxxxxx on behalf of the Company in the Certificate of Representations are true and correct. 4. The Company intends to continue to be organized and operate in a manner which will allow it to meet the requirements for qualification and taxation as a REIT for the remainder of the tax year ending December 31, 2013 and future years. 5. Each Subsidiary Partnership intends to continue to be organized and operate in a manner which will allow it to be treated as a partnership and not as an association taxable as a corporation for the remainder of the tax year ending December 31, 2013 and future years. 6. None of the securities to be issued pursuant to the Supplement will be issued in violation of the Limit as set forth in Article 11 of the Articles of Incorporation. 7. The Company is duly formed and existing under the laws of the State of Georgia and is duly authorized to transact business in the State of Georgia.

Significant Assumptions. Our opinion is expressly based upon any assumption set forth herein and as follows: 1. Beginning with the Company’s REIT election for the taxable year beginning January 1, 1987 and ending with the Company’s taxable year ending December 31, 20042005, the Company met the requirements for qualification as a REIT and was taxed as such. 2. Each Subsidiary Partnership was properly classified as a partnership for federal income tax purposes at all times prior to January 1, 20052006. 3. The facts and representations as made by Xxxxxxx Xxxxx Xxxxxx on behalf of the Company in the Certificate of Representations are true and correct. 4. The Company intends to continue to be organized and operate in a manner which will allow it to meet the requirements for qualification and taxation as a REIT for the remainder of the tax year ending December 31, 2013 2014 and future years. 5. Each Subsidiary Partnership intends to continue to be organized and operate in a manner which will allow it to be treated as a partnership and not as an association taxable as a corporation for the remainder of the tax year ending December 31, 2013 2014 and future years. 6. None of the securities to be issued pursuant to the Supplement will be issued in violation of the Limit as set forth in Article 11 of the Articles of Incorporation. 7. The Company is duly formed and existing under the laws of the State of Georgia and is duly authorized to transact business in the State of Georgia.

Significant Assumptions. Our opinion is expressly based upon any assumption set forth herein and as follows: 1. Beginning with the Company’s REIT election for the taxable year beginning January 1, 1987 and ending with the Company’s taxable year ending December 31, 20042005, the Company met the requirements for qualification as a REIT and was taxed as such. 2. Each Subsidiary Partnership was properly classified as a partnership for federal income tax purposes at all times prior to January 1, 20052006. 3. The facts and representations as made by Xxxxx Xxxxxx on behalf of the Company in the Certificate of Representations are true and correct. 4. The Company intends to continue to be organized and operate in a manner which will allow it to meet the requirements for qualification and taxation as a REIT for the remainder of the tax year ending December 31, 2013 2014 and future years. 5. Each Subsidiary Partnership intends to continue to be organized and operate in a manner which will allow it to be treated as a partnership and not as an association taxable as a corporation for the remainder of the tax year ending December 31, 2013 2014 and future years. 6. None of the securities to be issued pursuant to the Supplement will be issued in violation of the Limit as set forth in Article 11 of the Articles of Incorporation. 7. The Company is duly formed and existing under the laws of the State of Georgia and is duly authorized to transact business in the State of Georgia.