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I agree with Charlie Kohler but would like to add a couple of thoughts
....

1.  An opinion from the FSDO doesn't really mean much. If you really want
an opinion you (and others) can rely on, you have to write to the assistant
chief counsel at the FAA regional office in which you are located. State
your question clearly and don't ask your question too broadly ...... AND by
the way don't plan on getting an answer any time soon. They typically take
a month or more to respond. Alternatively you can call and ask to speak
with an FAA attorney and maybe get a verbal opinion which may give you some
indication of what's what. Subsequently you can (and please do) write a
letter.

It's possible that someone has already asked this question and the opinion
will come sooner rather than later. You might also ask EAA if they have any
documention that resolves this issue.

2. I have to agree with the "safe" comments but as I explained to one of my
charter clients who is considering buying a share of a fractional provider
(such as NetJets, etc.), there is no such thing as safe or unsafe. There is
only more safe and less safe.

Learn from the mistakes of others, you won't live long enough to make them
all yourself.

Ted Stanley

LML website:   http://www.olsusa.com/Users/Mkaye/maillist.html
LML Builders' Bookstore:   http://www.buildersbooks.com/lancair

Please send your photos and drawings to marvkaye@olsusa.com.