[Advogado]

To expand on my previous post, not only has the IRS never ruled that the CDD's paid less than the assets were worth, in its recent TAM, the IRS is still complaining about the size of the Developer's profits.

Furthermore, if taxable bonds had been used, the amenity fees would not have been higher. Using the income-stream-valuation methodology employed in the transaction, if taxable bonds had been used, the amenity fees would have stayed the same, but the Developer's profits would have been less.