I stand behind and beside Gracie, and re-iterate that the developer has captured a piece of heaven. Neither of us works for or is associated with the developer. That being said, IMHO, the ones likely to suffer any consequences from an adverse opinion from the IRS, would be the ones who directly benefited from the tax-exempt status. I do believe, however, that the issue will never be resolved.
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........American by birth....Union by choice
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