We do not have any hard evidence from the IRS on this matter.Your interpretation of what constitutes services is extreme, and based on the depth of our experience in this field, unfounded.  

You could try and build a case with enough evidence to go before a judge.  

Unless a resident that provides evidence that meets every criteria from HUD, we simply hand them a letter that the evidence they provided does  not meet the requirements for an ESA. 

That could be inferred, but was not evident, from your post.Are they willing to carry back financing?

I never signed a document nor invested my share of the capital.Friends have shown me evidence that the LLC that bears my name has purchased at least two properties and sold each.I am sure that laws have been broken.

Sometimes they even require a business plan or some evidence that you have done your homework and can take on the project. 

I thought we did a good enough job, but evidently we weren't thorough enough.

I had so much evidence against them that I basically told them to get bent and then stopped responding to their emails.

There is evidence of a substantial reduction in the opportunity to pick up 8+ units out in the Springfield area.

If fraud (and I emphasize 'If' as we don't have all the evidence available to us) is present I want to see those who perpetrated it brought to light and, at a minimum, held up for the public ridicule they deserve.