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HISTORIC BOARDWALK HALL, LLC v. COMMISSIONER

Docket No. 11273-07.

136 T.C. 1 (2011)

HISTORIC BOARDWALK HALL, LLC, NEW JERSEY SPORTS AND EXPOSITION AUTHORITY, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 3, 2011.

Attorney(s) appearing for the Case

Kevin M. Flynn and Michael Sardar , for petitioner.

Daniel A. Rosen , Curt M. Rubin , Molly H. Donohue , and Sashka T. Koleva , for respondent.

GOEKE, Judge:

Respondent issued a notice of final partnership administrative adjustment (FPAA) to Historic Boardwalk Hall, LLC (Historic Boardwalk Hall). The issues for decision are:

(1) Whether Historic Boardwalk Hall is a sham;

(2) whether Pitney Bowes was a partner in Historic Boardwalk Hall;

(3) whether New Jersey Sports and Exposition Authority (NJSEA or petitioner) transferred the benefits...

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