The law firm of Miller & Chevalier filed an amicus brief on December 21, 2011 to the Third Circuit of the United States Court of Appeals on behalf of the National Trust for Historic Preservation and other organizations in the IRS appeal of Historic Boardwalk Hall, LLC v. Commissioner. The outcome of this case could potentially have a far-reaching impact on the federal Historic Rehabilitation Tax Credit (HRTC). This amicus brief responded to a number of issues raised by the IRS in its appeal including the validity of using the economic substance doctrine in the context of the Congress’ intent of the HRTC and the legality of the partnership between Pitney Bowes and the New Jersey Sports and Exhibition Authority (NJSEA).
To view the amicus brief, click here.
