Tucson v. Commissioner
United States Tax Court
Petitioner, a political subdivision of the State of Arizona, proposes to issue bonds in the amount of $ 1 million to provide for certain public improvements.
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Petitioner, a political subdivision of the State of Arizona, proposes to issue bonds in the amount of $ 1 million to provide for certain public improvements. Debt service (i.e., principal and interest) on these bonds will be paid from a sinking fund which, during the period the bonds are outstanding, is expected to be invested in obligations not described in sec. 103(a), I.R.C. 1954. Petitioner seeks a declaratory judgment that the proposed bonds will be obligations described in sec. 103(a), I.R.C. 1954, and will not be arbitrage bonds within the meaning of sec. 103(c), I.R.C. 1954. Held,…
1Opinion of the Court
OPINION
Featherston, Judge:
This is an action for declaratory judgment filed pursuant to section 7478.2 On June 29, 1979, the city of Tucson, Ariz. (hereinafter petitioner or the city), requested respondent to rule that bonds in the amount of $1 million which petitioner proposes to issue will be obligations described in section 103(a)(1), so that the interest thereon will be excludable from the bond owners’ gross income. After lengthy administrative review, respondent denied the request, and this declaratory judgment action was filed. All jurisdictional requirements have been met. See Rule…
2Cases cited10 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- United States v. PriceSupreme Court of the United States · 1960
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
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3Cited by4 opinions
- City of Tucson, Arizona v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1987
- City of Tucson, Arizona v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1987
- City of Tucson, Arizona v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1987
- Tucson v. CommissionerUnited States Tax Court · 1982