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Originally Posted by Mr.Kris
Interestingly, from all of the publicly available documents I have reviewed, for the first time it appears the IRS is deemphasizing the original argument of whether the Issuer is a political subdivision and whether its debt is issued on behalf of a State or local governmental to the argument that under the 10% rule the bonds meet the private security or payment test. In other words, the argument is being moved from the subjective, i.e. is the issuer a government entity, to the objective, i.e. 10% rule. It's easier, in my opinion, to win an objective argument.
If you have been following this as deeply as I have, I would like much to hear from you and see your analysis. If you want to talk about your grandkids or dirty politicians not so much.
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I haven't followed the IRS case as closely as you have, and probably not enough. But one question I've had is..."what about the Disney CCD's and the bonds they've issued?"
My understanding has been that The Villages bond issuances for the construction of utilities, roads and common facilities in the districts were closely patterned after how Disney financed much of it's development in Orlando, particularly the City of Celebration and other residential developments they've done in and around the theme parks.
But I've never read about any IRS challenge of the Disney bonds. Or have I just missed that news?