Suppl. Response to IRS TAM On Political Subdivisions (TAM 2013)

Memorandum to supplement prior comments, dated November 21,2013, regarding concerns raised by the analysis set forth in Technical Advice Memorandum 201334038, dated August 23, 2013 (the “TAM”), with respect to the status of certain types of special purpose districts having a limited number of property owners, electors or taxpayers (“Districts”) as political subdivisions.