Support Cap

Support Cap. An amount equal to the aggregate taxes, penalties and interest paid by the Company to the IRS (including the amount paid in accordance with Section 875(b)(5) of the Code plus any related penalties, interest and additional amounts that may be paid by the Company to the IRS in connection therewith) for the Company's failure to satisfy the 75% gross income REIT test for the taxable year ended December 31, 2018 (the 75% REIT Test)