“The New Jersey Sports and Exposition Authority (NJSEA) formed the Historic Boardwalk Hall, LLC and then later Pitney Bowes entered into a tax-equity partnership with the NJSEA. As part of the tax-equity partnership Pitney Bowes would benefit by receiving a 99.9% ownership interest in the Historic Boardwalk Hall, LLC entity and be allocated historic rehabilitation tax credits that were generated by the partnership entity.

The IRS accused the NJSEA of selling tax credits to Pitney Bowes. Stating that the Historic Boardwalk Hall, LLC entity was a sham and that Pitney Bowes was never really a partner and that the NJSEA never actually transferred the ownership interest of the East Hall to the Historic Boardwalk Hall, LLC entity.”

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