As explained above in the link entitled History of Tics, the flood gates to the TIC industry opened when the IRS issued revenue procedure 2002-22 in March, 2002 to address the use of fractional ownership interests as replacement property in IRC section 1031 exchanges. The Revenue procedure 2002-22 is the result of this review. Although the IRS did not establish a safe harbor provision, it did spell out some requirements for TIC interests to qualify as
co-ownership interests.

The maximum number of tenants-in-common permitted is 35.

The sponsor or organizer of the interests may own the property (or an interest therein) for only six months before selling 100% of the units.

Unanimous decisions are required on anything of material or economic impact to the property or its owners.

The management agreement (if applicable) must be at a market rate and renewable annually.

Hopefully, you were informed of the above at the time of purchase. However, our investigation thus far has left us with the following questions:

1. Do you have contact information for all of your tenants in common?

2. If you do not, how can you make a unanimous decision ?

There are numerous business issues in operating real estate as you know from past experience. In the past you were the decision maker and could clearly implement a plan to stave off economic difficulties. Now what do you do in the event of the following:

- Reduced or negative cash flow

- Increasing delinquencies

- Bankrupt management

Our office believes other parties may be at fault for this situation. Please contact us to discuss a course of action which may protect your interests.