Indiana University Retirement Community, Inc. v. Commissioner
United States Tax Court
The city of Bloomington, Indiana, issued municipal bonds, the proceeds of which were to be used by P, a tax-exempt private foundation, to build retirement community facilities. During construction, P earned dividends and interest of $ 1,125,278 in 1982 and $ 226,505 in 1983 by investing the proceeds.
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The city of Bloomington, Indiana, issued municipal bonds, the proceeds of which were to be used by P, a tax-exempt private foundation, to build retirement community facilities. During construction, P earned dividends and interest of $ 1,125,278 in 1982 and $ 226,505 in 1983 by investing the proceeds. P also earned capital gains of $ 18,200 in 1983. In 1982 and 1983, P paid the interest due and payable on the debt underlying the bonds in the amounts of $ 1,348,447 for 1982 and $ 1,634,530 for 1983. Held, P may deduct the interest expense it paid on the debt underlying the bond issue from its…
1Opinion of the Court
Indiana University Retirement Community, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Indiana University Retirement Community, Inc. v. Commissioner
Docket No. 2493-88
United States Tax Court
92 T.C. 891; 1989 U.S. Tax Ct. LEXIS 61; 92 T.C. No. 56;
May 8, 1989. May 8, 1989, Filed
Decision will be entered for the petitioner.
The city of Bloomington, Indiana, issued municipal bonds, the proceeds of which were to be used by P, a tax-exempt private foundation, to build retirement community facilities. During construction, P earned dividends and interest of $ 1,125,278 in 1982 and $…
2Cases cited7 opinions
- United States v. GilmoreSupreme Court of the United States · 1963
- Lykes v. United StatesSupreme Court of the United States · 1952
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Lettie Pate Whitehead Foundation, Inc., Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1979
- Julia R. & Estelle L. Foundation, Inc. v. CommissionerUnited States Tax Court · 1978
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