Rome I, Ltd. v. Commissioner
United States Tax Court
This case was submitted for the limited purpose of deciding whether the partnership must recapture a portion of the rehabilitation tax credit and reduce its basis in the underlying rehabilitated property upon its donation of a historical facade easement in the same year it claimed the credit under sec. 48. The partnership was formed to acquire, rehabilitate, and operate commercial property.
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This case was submitted for the limited purpose of deciding whether the partnership must recapture a portion of the rehabilitation tax credit and reduce its basis in the underlying rehabilitated property upon its donation of a historical facade easement in the same year it claimed the credit under sec. 48. The partnership was formed to acquire, rehabilitate, and operate commercial property. The property consisted of a three-story building situated in a historic district, and was designated a certified historic structure within the meaning of sec. 48(g)(3) and sec. 1.48-12(d), Income Tax Regs.…
1Opinion of the Court
Rome I, Ltd., E.C. Systems, Inc., Tax Matters Partner, Petitioner v. Commissioner of Internal Revenue, Respondent
Rome I, Ltd. v. Commissioner
Docket Nos. 13017-88, 8590-89
United States Tax Court
96 T.C. 697; 1991 U.S. Tax Ct. LEXIS 35; 96 T.C. No. 29;
May 2, 1991, Filed
Decisions will be entered under Rule 155.
This case was submitted for the limited purpose of deciding whether the partnership must recapture a portion of the rehabilitation tax credit and reduce its basis in the underlying rehabilitated property upon its donation of a historical facade easement in the same year it claimed the…
2Cases cited17 opinions
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Stark v. CommissionerUnited States Tax Court · 1986
- Woods v. CommissionerUnited States Tax Court · 1988
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