(partnership investments used to rehabilitate property designated as "historic" in exchange for state "historic rehabilitation tax credits" held to be disguised sales; state law allows credits of up to 25% of cost to rehabilitate historic property and credits can be distributed among partners in a partnership for credits that are allocated to the partnership; IRS claimed that "partners" were not bona fide but, if they were, transactions were properly characterized as sales; transactions determined to be disguised sales under I.R.C. Sec. 707 and regulations; transfer of "property" involved because credits were "valuable" and had "some of the most essential property rights"; partners faced no risk (were promised refunds if credits weren't delivered; court's decision likely to trigger IRS appeal of decision in Historic Boardwalk Hall LLC v. Comr., 136 T.C. No. 1 (2011)).