Seaco said it owes the IRS $105 million.

The New York-based hotel, retail and real estate firm revealed that the Internal Revenue Service wants the firm to pay the $105 million, plus penalties and interest, for unpaid taxes from 1976 to 1981. Company President James Sherwood said the IRS claims that Seaco allowed another company to use some of its assets without proper compensation and now wants Seaco to pay taxes on the profits earned from those assets. Seaco said it would contest the claim, calling it “altogether unprecedented.”