Legal Opinion
Philadelphia National Bank and Philadelphia National Corporation v. United States
Court of Appeals for the Third Circuit
Decided December 11, 1981No. 81-1331PublishedCited by 16 opinions
1Opinion of the Court
OPINION OF THE COURT
WEIS, Circuit Judge.
Interest on money borrowed by political subdivisions is exempt from federal income tax. In this case, the district court concluded that Temple University, a state-related school in Pennsylvania, had sufficient governmental functions and powers to qualify as a political subdivision. Our review of the record, however, persuades us that although the university has close ties with and is dependent upon the state, a delegation of essential governmental power did not take place. Accordingly, we reverse a judgment in favor of the plaintiff bank which had…
2Cases cited13 opinions
- Burton v. Wilmington Parking AuthoritySupreme Court of the United States · 1961
- Chicago, Burlington & Quincy Railway Co. v. Illinois ex rel. Drainage CommissionersSupreme Court of the United States · 1906
- Carl E. Weller and Emily I. Weller v. Commissioner of Internal Revenue, W. Stuart Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Mutual Loan Co. v. MartellSupreme Court of the United States · 1911
- Braden v. University of PittsburghCourt of Appeals for the Third Circuit · 1977
8 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Krynicky v. University of PittsburghCourt of Appeals for the Third Circuit · 1984
- State of Michigan and Michigan Education Trust v. United StatesCourt of Appeals for the Sixth Circuit · 1995
- Texas Learning Technology Group v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1992
- Rose v. Long Island Railroad Pension PlanCourt of Appeals for the Second Circuit · 1987
- Krupp v. Lincoln UniversityDistrict Court, E.D. Pennsylvania · 1987
11 more not listed; retrieve them via the Exa API.