It is much more difficult to qualify for the credits if you don’t submit the Part 1 and 2 applications before beginning work, but it may be possible. You must have good photographs showing the building before the rehabilitation work began, as described in the preceding section. If you do not have this documentation, it will not be possible to evaluate the proposed and completed project. Additionally, all work which you have already completed must meet the Standards – any work that does not meet the Standards would need to be remediated in order for the overall project to be approved.
Failure to submit the Part 1 application before completing work is not necessarily fatal to the State Program, provided that all other requirements of the program are met. However, the deadline for application for participation the State Program is one year after your completion date, which is either the date of the Certificate of Occupancy -or- the date of the final eligible physical rehabilitation expenditure. You must submit a complete, fully documented Part 1, Part 2, and Part 3 application by this date in order to qualify for the State credit.
If you have already completed your rehabilitation work, and your building is not individually listed on the National Register, you cannot qualify for the Federal credit. The IRS has taken a strong position that if the Part 1 application has not been submitted before the building is placed in service, it is not a “Certified Historic Building”, and the Federal credit is not available. Please note that a Part 1 application is required for all properties that are individually listed on the National Register except in cases where there is only one building on the property and there are no other resources.