Fraud has to be intentional to avoid paying taxes. No one has suggested OPA did that over the years of the dispute.

Found this on the web: "Another rule with the IRS that can fall under that Statute of Limitations is that if the IRS does not assess taxes within a three year period of the tax return being filed, they cannot legally collect those taxes that you would have owed. This is extremely rare that an agent misses the Statute of Limitations in a case like this, but errors are sometimes made and a taxpayer can get away with not paying a penny of whatever the tax amount owed was."

To my knowledge only the 2003-2004 fiscal years were ever audited and actually assessed by IRS. OPA lost the legal challenge, is now writing off a total of $459,000 as the total tax obligation at this point (less the $119,000 already paid in order to go forward with the appeal).

Are some upset that it wasn't more, and now wish to argue it should be more?