Research Problem 1. During a recent Sunday afternoon excursion, Miriam, an admirer of early twentieth-century architecture, discovers a 1920s-era house in the countryside outside Mobile, Alabama. She wants not only to purchase and renovate the house but also to move the structure into Mobile so that her community can enjoy its architectural features.

Being aware of the availability of the tax credit for rehabilitation expenditures, she wants to maximize her use of the provision, if it is available in this case, once the renovation work begins in Mobile. However, Miriam informs you that she will pursue the purchase, relocation, and renovation of the house only if the tax credit is available.

Comment on Miriam’s decision and on whether any renovation expenditures incurred will qualify for the tax credit for rehabilitation expenditures.

Partial list of research aids:

George S. Nalle III v. Comm., 72 AFTR 2d 93–5705, 997 F.2d 1134, 93–2 USTC ¶50,468 (CA–5, 1993).