What is the earliest date by which a CRD allocation can be made?
The CRD allocation can be made at any time, starting in 2002, provided it is made under a qualified allocation plan that has been approved by the governmental unit of which the Commercial Revitalization Agency (CRA) is a part. The CRA must also notify the CEO of the local jurisdiction in which the building is located of the allocation and give that individual a reasonable opportunity to comment on the allocation. If the allocation is made in calendar year 2002, IRC section 42(h)(1) requires that: (a) The building is placed in service by December 31, 2002, OR (b) The building is placed in service no later than December 2004, AND the taxpayer’s basis in the project in which the building is a part (as of 6 months after the date the allocation was mad or, if later, December 31, 2002) is at least 10% of the taxpayer’s reasonably expected basis in the project (as of the end of 2004). However, if it is determined that the building may not meet either the deadline, IRC section 42(h)(1) (C) all
