My interpretation of a one time estoppel fee required by lender, functions in a similar fashion as title assurance. That is, it is to provide transparency that there are no unknown liens or fees assessed by the HOA to an unsuspecting buyer.
Normal HOA fees for a personal residence are not deductible or added to basis. But in this scenario, the certificate functions unlike typical HOA fees and that is how I'm basing my interpretation - its function.
There is no precedent for deducting HOA estoppel fees. If in doubt, then the more conservative opinion should prevail.
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