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
City of Tucson, Arizona, Petitioner v. Commissioner of Internal Revenue, Respondent
Tucson v. Commissioner
Docket No. 3889-80B
United States Tax Court
78 T.C. 767; 1982 U.S. Tax Ct. LEXIS 103; 78 T.C. No. 52;
April 29, 1982, Filed
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),…
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
- 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
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
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