SECTION 12. DRAFTING

INFORMATION

The principal author of this revenue procedure is Emily Kalovidouris of the Office of Associate Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue procedure, contact Ms. Kalovidouris at (202) 622–3110 (not a toll-free call).

locations made in 2002, and to any allocation document made in 2002:

.01 Unallocated portion of 2002 ceil- ing . The $12 million commercial revitalization expenditure ceiling for 2003 for a renewal community is increased by any portion of the 2002 commercial revitalization expenditure ceiling for that renewal community that was not allocated in 2002. For example, if State A has only one renewal community, RC, and only $7 million of the $12 million commercial revitalization expenditure ceiling for 2002 for RC was allocated to qualified revitalization buildings in RC in 2002, the commercial revitalization expenditure ceiling for 2003 for RC in State A is $17 million. .02 Aggregation of 2002 ceiling . The 2002 commercial revitalization expenditure ceiling for each renewal community within a state may be aggregated and apportioned to any renewal community within the state. However, after 2002, no aggregation of the ceiling is permitted, including any portion of the 2003 ceiling that is attributable to the unallocated portion of the 2002 ceiling in accordance with section 8.01 of this revenue procedure ( see section 3.03 of this revenue procedure).

For example, State B has two renewal communities, RC1 and RC2. For 2002, State B aggregated the $12 million ceilings for RC1 and RC2 resulting in a total 2002 ceiling of $24 million. Of that amount, $15 million was apportioned to RC1 and $9 million was apportioned to RC2 for 2002. This aggregation and apportionment of the 2002 ceiling for RC1 and RC2 are permitted pursuant to section 8.02 of this revenue procedure. In 2002, $12 million of the $15 million of RC1’s 2002 ceiling was allocated to qualified revitalization buildings in RC1 and $7 million of the $9 million of RC2’s 2002 ceiling was allocated to qualified revitalization buildings in RC2. Pursuant to sections 3.03 and 8.01 of this revenue procedure, the commercial revitalization expenditure ceiling for 2003 for RC1 is $15 million ($12 million ceiling for 2003 plus the $3 million not allocated from the 2002 ceiling) and for RC2 is $14 million ($12 million ceiling for 2003 plus the $2 million not allocated from the 2002 ceil

ing). In accordance with sections 3.03 and 8.02 of this revenue procedure, the $15 million ceiling for 2003 for RC1 and the $14 million ceiling for 2003 for RC2 may not be aggregated and apportioned.

.03 Carryover allocation . If a carryover allocation is made after June 30, 2002, and before January 1, 2003, the taxpayer must meet the 10 percent basis requirement set forth in section 6.01(1) of this revenue procedure by December 31, 2003.

.04 Allocation document . Any allocation document made in 2002 that is not made in the manner prescribed in section 4.02 or 6.02 of this revenue procedure, as applicable, will be deemed to meet the requirements of section 4.02 or 6.02 of this revenue procedure, as applicable, if the document contains sufficient information to identify the commercial revitalization agency, the taxpayer, the qualified revitalization building, the date of the allocation, and the commercial revitalization expenditure amount allocated to the qualified revitalization building in a singlebuilding project or to the multi-building project, as applicable.