Historic Boardwalk Hall, LLC, et al. v. Comr., 694 F.3d 425 (2012), rev'g., 136 T.C. 1 (2011)

(case involves federal historic rehabilitation tax credit (HRTC) as continued in the Tax Reform Act of 1986 that is available to owners of building; plaintiff owned building in question and Pitney Bowes Corporation was partner of plaintiff (C corporations are not subject to at-risk and passive activity loss rules); IRS took position that plaintiff merely vehicle to transfer HRTC to Pitney Bowes and that all HRTCs should be reallocated to New Jersey Sports and Exposition Authority; Tax Court ruled for plaintiff and allocated HRTCs to Pitney Bowes; on appeal, court reversed because Pitney Bowes did not have "meaningful stake" in plaintiff's success or failure and, as such, was not a bona fide partner in plaintiff).