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5/17/2016 12:15:32 PM
 
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Section 5: OPA Board Subject: Tax Status Msg# 949846
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In my opinion, the case was correctly decided against OPA at both courts.
Jim. Is it also your opinion that the basis for the courts decision was that our Beach Club and Beach Club parking were not open to the public? Seems that the physical location of the Beach Club and parking, while a fact, was not the basis of the courts holding in favor of the IRS. |
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For reference, the above message is a reply to a message where: Joe: In considering court opinions, it is a poor practice to extract words, phrases, or sentences from an opinion to make a point. What you highlighted is not the opinion, but extracted from the Background of the opinion among many other details of OPA. Go to the actual discussion in the opinion and find a basis, if you can, that indicates that physical location was relevant to the decision. Also, you have copied the Tax Court opinion. The case was appealed to the 4th Federal Circuit. That is the relevant opinion. In my opinion, the case was correctly decided against OPA at both courts Jim Trummel |
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