I agree, that was a slip of the pen.

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.

I have no argument with that.  The point I tried to make is there is liability for the years after 2004 (excluding 2011 when OPA began selling passes) and OPA has only estimated that liability and maybe with the assumption that penalties will not be assessed, maybe interest too.  The IRS can audit those years.  In my opinion OPA should amend our taxes for those years and pay the taxes that are due.  We should not wait for IRS audit.

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.

That's what I am referring as stated above.

Has OPA paid all that to IRS? I'm not sure.

Based on the press release and the Board's discourse after the lawsuit decision, I believe as stated in the press release they have estimated the additional liability and they are writing that off.  I do not believe it was paid.  I believe there is no intention to pay unless the IRS comes calling again.  And if the IRS comes calling again there may be interest and penalties that are accruing on the additional liability.

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,

I agree.  I have no argument from 2011 going forward.

Here is an interesting question.  There is no statue of limitations on fraud.  If OPA estimates their liability and writes if off, but does not actually pay it, is that fraud?