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5/17/2016 1:06:15 PM
 
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Section 5: OPA Board Subject: Tax Status Msg# 949872
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I don't see the location reference to be anything but the existing fact of the facility. Nothing else. It is among the facilities owned by OPA and that is the location.
Again, where in the discussion part of the opinion(s) do you find anything to support location being relevant? How likely do you think it is that another HOA with a similar scenario, but the facility within the boundaries of the HOA, will distinguish its case from OPA on that fact and dispute an IRS claim of tax liability? Jim Trummel |
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For reference, the above message is a reply to a message where: In my opinion, the case was correctly decided against OPA at both courts Thanks. I was not debating the decision. What is your view in terms of the emphasis on the word "community" and the fact that it was pointed out that the parking and Beach Club was 8 miles from the community here. |
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