connection with the first leg of the reverse
exchange:
A Qualified Exchange Accommodation Agreement ("QEAA") Revenue Procedure
2000-37 requires that the taxpayer and the Exchange Accommodation Titleholder enter into ... Revenue Procedure 2000-37. As required by Revenue Procedure 2000-37, the QEAA
specifies that the Exchange Accommodation Titleholder will be treated as the beneficial owner
of the Replacement Aircraft ... copies by
overnight courier back to us.
(4) Sign two (2) copies of the QEAA, but do not date the documents. Please overnight both
copies of the signed QEAA