City of Santa Rosa, California v. Commissioner

120 T.C. No. 12

UNITED STATES TAX COURT CITY OF SANTA ROSA, CALIFORNIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7310-00B. Filed May 13, 2003. 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…