City of New York v. Commissioner
United States Tax Court
Petitioner, a municipal corporation of the State of New York, seeks a declaratory judgment that the bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. Petitioner proposes to use $ 15 million of the $ 100 million bond issuance to finance advances to nongovernmental borrowers for purposes of rehabilitating low-income housing units.
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Petitioner, a municipal corporation of the State of New York, seeks a declaratory judgment that the bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. Petitioner proposes to use $ 15 million of the $ 100 million bond issuance to finance advances to nongovernmental borrowers for purposes of rehabilitating low-income housing units. The advances will be structured as loans that must be repaid in full by the borrowers, and will bear interest rates below the market rate reflected in the yield on the bonds. Held, petitioner may not use time value of money principles…
1Opinion of the Court
City of New York, Petitioner v. Commissioner of Internal Revenue, Respondent
City of New York v. Commissioner
Docket No. 27960-92B
United States Tax Court
103 T.C. 481; 1994 U.S. Tax Ct. LEXIS 70; 103 T.C. No. 27;
October 11, 1994, Filed
Decision will be entered for respondent.
Petitioner, a municipal corporation of the State of New York, seeks a declaratory judgment that the bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. Petitioner proposes to use $ 15 million of the $ 100 million bond issuance to finance advances to nongovernmental borrowers for purposes of…
2Cases cited26 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Commissioner v. BrownSupreme Court of the United States · 1965
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Humes v. United StatesSupreme Court of the United States · 1928
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