Historic Boardwalk Hall, LLC v. Comm'r
United States Tax Court
New Jersey Sports and Exposition Authority (NJSEA) and Pitney Bowes (PB) formed Historic Boardwalk Hall, LLC, to allow PB to invest in the historic rehabilitation of the East Hall, a popular convention center in Atlantic City, New Jersey. The East Hall underwent a significant rehabilitation during the years at issue. On Forms 1065, U.S.
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New Jersey Sports and Exposition Authority (NJSEA) and Pitney Bowes (PB) formed Historic Boardwalk Hall, LLC, to allow PB to invest in the historic rehabilitation of the East Hall, a popular convention center in Atlantic City, New Jersey. The East Hall underwent a significant rehabilitation during the years at issue. On Forms 1065, U.S. Return of Partnership Income, for 2000, 2001, and 2002, Historic Boardwalk Hall claimed qualified rehabilitation expenditures and allocated those expenditures to PB, allowing PB to claim historic rehabilitation tax credits pursuant to sec. 47, I.R.C. R issued…
1Opinion of the Court
Goeke, Judge:
Respondent issued a notice of final partnership administrative adjustment (fpaa) to Historic Boardwalk Hall, llc (Historic Boardwalk Hall). The issues for decision are:(1) Whether Historic Boardwalk Hall is a sham;(2) whether Pitney Bowes was a partner in Historic Boardwalk Hall;(3) whether New Jersey Sports and Exposition Authority (njsea or petitioner) transferred the benefits and burdens of ownership of the East Hall to Historic Boardwalk Hall; and(4) whether Historic Boardwalk Hall is liable for section 66621 accuracy-related penalties for years 2000, 2001, and 2002.
FINDINGS…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- Luna v. CommissionerUnited States Tax Court · 1964
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