The Historic Boardwalk Hall Case in which the Internal Revenue Service challenged the traditional structure used by tax credit investors in the syndication of Federal Historic Tax Credits came to an uncerimonial end with the denial by the United State Supreme Cout of the taxpayer's writ of certiorari to the high court.  As reported in an earlier entry on this blog, the Service has announced its intention to provide guidance, most likely in the form of a Revenue Procedure, which  will provide a safe harbor for investors in Federal Historic Tax Credits.  It is anticipated that the safe harbor will reflect the position of the Service in the Historic Boardwalk Hall Case and an investor must demonstrate that it is a partner for Federal income tax purposes with downside risk and upside potential as a partner.