Split ownership no problem under Sec. 142

A newly posted IRS Private Letter Ruling (PLR) has found that the whole of a bond-funded building can still be a "qualified residential rental project" under Sec. 142 of the Code where one partnership owns the market-rate rental units, a different partnership owns the subsidized units, and the two types of units are "interspersed throughout the building." The PLR, which is No. 200601021, appeared publicly on Friday, Jan. 6, 2006 but was apparently written in December 2004 and issued in July 2005. There's no explanation for the mildly unusual delay before its public disclosure. As always, a PLR may not be cited as precedent.