WASHINGTON — The Internal Revenue Service’s chief counsel has tentatively concluded that at least $364 million of recreational revenue and subordinate recreational refunding bonds issued by the Florida Village Center Community Development District between 1998 and 2003 are not tax-exempt.

The Florida CDD disclosed the IRS’ finding in an event notice filed with the Municipal Securities Rulemaking Board’s EMMA system late Wednesday evening, saying the chief counsel verbally communicated that it had “tentatively” concluded that the CDD is not a political subdivision.

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