I believe IRS only waived penalties, not interest.

But I would love to be wrong. I would love to know that the IRS accepted a total payment of $459,000 and the entire issue is closed.

IRS rarely "accepts" anything.  OPA had to pay the tax and interest on 2003 and 2004 before the case could go to court. That was around $119,000. IRS did no audit after the 2004 year. When the case was finally settled on the original lawsuit it meant that IRS kept the tax and interest from 2003-2004. Period.

Now, based on the court case result, OPA needed to move forward with a plan for selling parking passes that met the criteria to avoid tax on the income as came out in the court. OPA has done that, based on advice of counsel, and will not be paying taxes from here on out unless the IRS challenges how OPA handles selling the passes to those who are not association members.

After 2004, since IRS has done no audits, there are a number of years where the statute of limitations was reached. There are, however, two or three years where the statute of limitations was not reached. Liability for those years is why the write-off last year was around $500,000.

Has OPA paid all that to IRS? I'm not sure. However, I do believe in the year the court decisioopn was finalized that OPA included the beach club parking in the tax return and paid the tax. Thereafter the passes were available to the general public and the income is therefore not taxable.... unless and until some court says otherwise.

For years after 2004 and prior to the final court decision but not yet covered by the statute of limitations, it may be OPA is waiting to see if there is an audit of any year where the statute of limitations has not expired before just sending the IRS money.

Frankly I think some in the community want OPA to owe more to the IRS.

I have no problem with how OPA has handled this.