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
OPINION
COLVIN, Judge:
This is a proceeding pursuant to section 6226 for a readjustment of partnership items of Rome I, Ltd., a partnership, for the taxable year ending December 31, 1984. The facts of this case have been fully stipulated, and are so found. The relevant facts are summarized below.
After concessions, the sole issue in this case is 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 section 48. As…
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