5/17/2016 5:32:16 PM
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Section 5: OPA Board Subject: Tax Status Msg# 949910
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Jim:
I hope you don't think I was insinuating that you are not competent? Not true. I have the highest respect for you and your opinion. Now, that said, let's talk about the OPA amenities other than the Beach Parking which I would argue is an anomaly. I do not believe for even one second that anyone, IRS or otherwise, expects the property owners/OPA members, to invest in maintaining and improving amenities, which for the most part are located inside of what was not all that long ago a private and gated community, for public use by others. It defies any common sense. Marty |
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For reference, the above message is a reply to a message where: What do you expect a "competent" tax attorney will do much beyond referring you to the Beach Club parking 4th Circuit decision? I think it is reasonably clear that the Unrelated Business Income Tax would come under consideration for any amenity not open to the public. I don't have any interest in pursuing a discussion based on the perception that several are money losing. Attribution of revenues may not be as straight forward as it seems. Jim Trummel |
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