Hotel Partnership Gets Transfer Taxes Slashed In IRS Row

Law360, New York (January 9, 2014, 8:48 PM EST) -- The U.S. Tax Court ruled Thursday that a partnership responsible for rehabilitating historic hotels in St. Louis, Mo., wasn't fully liable for taxes on $18.4 million it earned by transferring historic preservation tax credits because some transfers were done within the partnership.

Gateway Hotel Partners LLC transferred the credits three times to a real estate developer that obtained $18.4 million in financing for a redevelopment project, which then transferred the credits to another company under a tax credit purchase agreement. When Gateway filed its tax returns,...
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