A Florida community development district's lawyer is urging the Internal Revenue Service's chief counsel to reconsider a ruling against the CDD, arguing it is incorrect, biased, lacks legal analysis and ignores precedent.

"The result of the failings of the [technical advice memorandum] ... is to target the [Village Center Community Development District] through innuendo and through the attempted creation of new legal standards not set forth in any previous law or guidance," Perry Israel, a lawyer based in Sacramento representing the CDD, wrote in a four-page letter to IRS chief counsel William J. Wilkins.

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