WASHINGTON — The Internal Revenue Service has closed its audit with no change to the tax-exempt status of $19.04 million of tax-increment refunding revenue bonds that were issued in 2003 by the Florissant, Mo., Industrial Development Authority.
The IRS informed the issuer of the audit’s closure in a May 7 letter, according to the event notice the IDA filed late last week with the Municipal Securities Rulemaking Board’s EMMA system.
The IRS had opened the audit on May 18, 2010, according to the IDA, which disclosed the audit in June 2011.
The IDA had responded to several requests for information from the IRS and had hired Gilmore & Bell PC as its special tax counsel for the audit.
Gilmore & Bell was also bond counsel for the 2003 transaction.
The bonds were issued to refund some tax-increment notes the city had previously issued to help finance the Cross Keys Redevelopment Project, which was trying to alleviate some of the “blighting” conditions, according to the official statement.
The redevelopment area covered about 46 acres and the project involved the reconstruction of a 335,000-square-foot retail development, which included shops and parking.
The bonds were payable, in part, from the proceeds or a sales tax collected within a transportation development.
The IRS auditor had primarily focused on the status of the transportation development district sales tax as a “generally applicable tax” as that term is defined in federal income tax regulations, according to the IDA.
Lawyers with Gilmore & Bell declined to comment.
The underwriter in the transaction was Stifel, Nicolaus & Co. in St. Louis. Counsel to the IDA was Lewis, Rice and Fingerish in St. Louis and counsel to the developer was Husch & Eppenberger LLC, now Husch Blackwell LLP in St. Louis.
