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
Fairfax County Economic Development Authority, Petitioner v. Commissioner of Internal Revenue, Respondent
Fairfax County Economic Development Authority v. Commissioner
Docket No. 8296-80B
United States Tax Court
77 T.C. 546; 1981 U.S. Tax Ct. LEXIS 65;
September 2, 1981, Filed
Decision will be entered for the respondent.
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…
2Cases cited20 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
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