City of Columbus v. Commissioner
United States Tax Court
P, a home rule municipal corporation and political subdivision of the State of Ohio, seeks a declaratory judgment that interest on bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. In 1967, in exchange for the assumption of P's accrued unfunded pension obligation by a fund established for that purpose by the State of Ohio, P incurred a long-term obligation to the State Fund.
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P, a home rule municipal corporation and political subdivision of the State of Ohio, seeks a declaratory judgment that interest on bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. In 1967, in exchange for the assumption of P's accrued unfunded pension obligation by a fund established for that purpose by the State of Ohio, P incurred a long-term obligation to the State Fund. In 1994, P made a lump-sum payment equal to 65 percent of the remaining principal in satisfaction of the long-term obligation. Taking into account the 35-percent discount, the yield to P in…
1Opinion of the Court
OPINION
Tannenwald, Judge:
This is an action for a declaratory judgment pursuant to section 7478 and Rule 211.1 On June 3, 1994, petitioner submitted a ruling request to respondent seeking a determination that interest on certain proposed bonds will be excludable from gross income under section 103(a). After administrative review, on December 5, 1994, respondent ruled that interest on the proposed bonds will not be excludable under section 103(a) on the grounds that the bonds would be arbitrage and/or hedge bonds within the meaning of sections .148 and 149(g), respectively. All of the…
2Cases cited3 opinions
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Santa Fe Pacific Corporation v. Central States, Southeast and Southwest Areas Pension FundCourt of Appeals for the Seventh Circuit · 1994
- Coca-Cola Co. v. CommissionerUnited States Tax Court · 1996
3Cited by4 opinions
- City of Columbus v. CommissionerUnited States Tax Court · 1996
- City of Columbus v. CommissionerUnited States Tax Court · 1998
- City of Columbus v. CommissionerUnited States Tax Court · 1996
- City of Columbus, Ohio v. CommissionerUnited States Tax Court · 1996