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REHEARING PETITION FILED IN BOARDWALK HALL

Monday, October 15, 2012 - 7:00AM

The taxpayer in Historic Boardwalk Hall (HBH) v. Commissioner filed a petition for rehearing or rehearing en banc of the U.S. 3rd Circuit Court of Appeals’ Aug. 27 panel opinion that denied historic rehabilitation tax credits to investor Pitney Bowes. The petition argues that the panel’s opinion is contrary to precedent and uses the wrong standard of review, that it wrongfully treats the historic tax credit allocation to the investor as a repayment of capital to the investor by the partnership, and that its risk analysis erroneously treats the tax credits as property to be transferred or sold. The petition does not list a deadline for the court to respond.

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