United States
Securities and Exchange Commission
Washington, D.C.   20549

Form 12b-25

Notification of Late Filing

(Check one):
___ Form 10-K __ Form 20-F __ Form 11-K  ___ Form 10-Q    X  Form N-SAR

For the Period Ended:            12/31/04

Part I - Registrant Information

Full Name of Registrant

Cohen & Steers Total Return Realty Fund Inc

Former Name if Applicable



Address of Principal Executive Office (Street & Number)

757 Third Avenue 
New York, NY 10017

Part II - Rules 12b-25(b) and (c)

If the subject report could not be filed without unreasonable effort or 
expense and the registrant seeks relief pursuant to Rule 12b-25(b), the 
following should be completed.

(a) the reasons  described in  reasonable  detail in Part III of this 
form could not be eliminated without unreasonable effort or expense.

(b) The subject annual report, semi-annual report, transition  
report on Form 10-K,  Form 20-F,  11-K,  Form N-SAR, or portion  
thereof, will be filed on or before the  fifteenth calendar day 
following the  prescribed  due date; or the subject quarterly report 
transition report on form 10-Q, or portion thereof will be filed on or 
before the fifth calendar day following the prescribed due date

(c)     The accountant's statement or other exhibit required by Rule 
12b-25(c)has been attached if applicable

Part III - Narrative

State below in reasonable detail the reasons why the Form 10-K, 11-
K, 10-Q, N-SAR, or the transition report or portion thereof, could 
not be filed within the prescribed time period.

The registrant requests additional time to file form NSAR so that it 
can compile the necessary information to file a complete and accurate 
document.

Part IV - Other Information

(1)     Name and telephone number of person to contact in regard to 
this notification

        Adam Derechin, Vice President  
        (212) 832-3232

(2)     Have all other periodic reports required under Section 13 or 
15(d) of the Securities Exchange Act of 1934 or Section 30 of the 
Investment Company Act of 1940 during the preceding 12 months been 
filed?

                Yes

(3) Is it anticipated that any significant change in results of 
operations from the  corresponding  period for the last  fiscal  year 
will be reflected  by the earnings statements to be included in the 
subject report or portion thereof?

        No

(Name of Registrant as Specified in Charter)    Cohen & Steers Total Return Realty Fund Inc  

has caused this notification to be signed on its behalf by the 
undersigned hereunto duly authorized.

Date:   3/1/05	                            By:     Rick Magliaro
                                              /s/:    Rick Magliaro