### Question
How does ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES define closely held real estate investment trust?


### Answer
Under *26 U.S.C. § 6655*, **closely held real estate investment trust** is defined as:

> a real estate investment trust with respect to which 5 or fewer persons own (after application of subsection (d)(5) of section 856) 50 percent or more (by vote or value) of the stock or beneficial interests in the trust

#### Citation:
  - *26 U.S.C. § 6655*
  - Heading: **Subtitle F-Procedure and Administration > CHAPTER 68-ADDITIONS TO THE TAX, ADDITIONAL AMOUNTS, AND ASSESSABLE PENALTIES > Subchapter A-Additions to the Tax and Additional Amounts > PART I-GENERAL PROVISIONS**

