Legal Opinion

City of Santa Rosa v. Comm'r

United States Tax Court

Decided May 13, 2003No. 7310-00BPublished

P petitions this Court pursuant to sec. 7478, I.R.C., seeking a declaration that interest on certain bonds will be exempt from taxation under sec. 103(a), I.R.C. P proposes to issue bonds of $ 140 million to finance the construction of a pipeline. The pipeline will dispose of wastewater generated in P's subregional sewage and water reclamation system.

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P petitions this Court pursuant to sec. 7478, I.R.C., seeking a declaration that interest on certain bonds will be exempt from taxation under sec. 103(a), I.R.C. P proposes to issue bonds of $ 140 million to finance the construction of a pipeline. The pipeline will dispose of wastewater generated in P's subregional sewage and water reclamation system. P has entered into an agreement obligating P to deliver, and a utility company to accept, an average of 11 million gallons of wastewater per day. The utility company will use the wastewater to activate geysers and produce steam for the…

1Opinion of the Court

CITY OF SANTA ROSA, CALIFORNIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

City of Santa Rosa v. Comm'r

No. 7310-00B

United States Tax Court

120 T.C. 339; 2003 U.S. Tax Ct. LEXIS 14; 120 T.C. No. 12;

May 13, 2003, Filed

Judgment entered for petitioner.

P petitions this Court pursuant to sec. 7478, I.R.C.,

seeking a declaration that interest on certain bonds will be

exempt from taxation under sec. 103(a), I.R.C. P proposes to

issue bonds of $ 140 million to finance the construction of a

pipeline. The pipeline will dispose of wastewater generated in

P's subregional sewage and water…

2Cases cited3 opinions

  1. City of New York v. CommissionerUnited States Tax Court · 1994
  2. City of New York v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1995
  3. City of Santa Rosa v. Comm'rUnited States Tax Court · 2003

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