Fairfax County Economic Development Authority v. Commissioner
United States Tax Court
Petitioner, a governmental authority described in sec. 103(a), I.R.C. 1954 (see sec. 1.103-1(b), Income Tax Regs.), is authorized to issue bonds which are payable solely from the revenues and receipts derived from the leasing or sale of its facilities. It proposes to issue its bonds and use the proceeds to purchase from Limited Partnership S a facility which S is building to lease to the U.S.
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Petitioner, a governmental authority described in sec. 103(a), I.R.C. 1954 (see sec. 1.103-1(b), Income Tax Regs.), is authorized to issue bonds which are payable solely from the revenues and receipts derived from the leasing or sale of its facilities. It proposes to issue its bonds and use the proceeds to purchase from Limited Partnership S a facility which S is building to lease to the U.S. Government Printing Office (GPO). S would then repurchase the facility from petitioner using an installment sales contract. Held: Although, in an economic sense the United States may be the "real…
1Opinion of the Court
OPINION
Tannenwald, Chief Judge:
This is an action for declaratory judgment pursuant to section 7478.1 The case was submitted for decision under Rule 122, on the basis of the administrative record and a stipulation of facts. See Rule 217. Petitioner has satisfied all the jurisdictional requirements. See Rule 210(c). The sole question presented is whether the proposed bonds are industrial development bonds which are exempt from Federal income taxes. Resolution of this question depends upon (1) whether the proposed bonds would be obligations of the United States; (2) whether the Federal…
2Cases cited19 opinions
- Myers v. United StatesSupreme Court of the United States · 1926
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Barr v. United StatesSupreme Court of the United States · 1945
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- Ohio v. HelveringSupreme Court of the United States · 1934
14 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Washington v. CommissionerUnited States Tax Court · 1981
- Tucson v. CommissionerUnited States Tax Court · 1982
- Fairfax County Economic Development Authority v. CommissionerUnited States Tax Court · 1981
- Fairfax County Economic Development Authority v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1982
- Tucson v. CommissionerUnited States Tax Court · 1982
2 more not listed; retrieve them via the Exa API.