A real estate investment trust (REIT) partnership that failed to file Form 972, Consent of Shareholder to Include Specific Amount in Gross Income, and Form 973, Corporation Claim for Deduction for Consent Dividends, with respect to a declared dividend amount received extra time to perfect the desired election. A consent dividend, the IRS explained, is a hypothetical distribution (as distinguished from an actual one) made by certain corporations to any person who owns consent stock on the last day of the corporation’s taxable year and agrees to treat it as an actual dividend. According to the representation, Taxpayer’s ...
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