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Rehabilitation of Everett Mill/Kunhardt Mill Properties
On May 16, 1986, Mr. Sidell submitted a historical
preservation application to the U.S. Department of the Interior
requesting certification that the Everett Mill property was a
"certified historic structure". Certification was subsequently
granted by the National Park Service (Park Service). Thereafter,
in 1989 and 1990, substantial rehabilitation, repairs, and
modifications were made to the Everett Mill property. Petitioners
claimed rehabilitation credits for the rehabilitation expenditures
in 1989 and 1990. The rehabilitation credits for these years were
allowed and are not at issue in this case.
Seeking similar tax treatment for the Kunhardt Mill property,
and concurrently with its acquisition, Mr. Sidell (on behalf of CFS
Realty Trust) instituted a major rehabilitation project with
respect to the property. After repairs and renovations had begun
on the Kunhardt Mill property, Mr. Sidell submitted a historic
preservation certification application on March 23, 1993, to the
U.S. Department of the Interior seeking a determination that the
work previously done on the property conformed with its "Standards
for Rehabilitation". After Mr. Sidell completed the rehabilitation
project, the Park Service preliminarily determined that the work
performed on the Kunhardt Mill property was eligible for "certified
rehabilitation" status. Subsequently, on September 23, 1994, Mr.
Sidell submitted a "Historic Preservation Certification Application
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Last modified: May 25, 2011