LTR 201150023 allowed a taxpayer to obtain an exemption for income by voluntarily accelerating the income.
The taxpayer is a REIT that converted from C corporation status and thereafter sold property (through disregarded entities) to a lower tier subsidiary of a taxable REIT subsidiary. The sale had been on the installment method taxed under section 453, evidently with no installment to be paid within the ten year recognition period for built in gain taxation under section 1374.
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