California Health Facilities Authority v. Commissioner
United States Tax Court
P proposes to issue bonds pursuant to an indenture between P and a corporate trustee and seeks a declaratory judgment that such bonds would be described in sec. 103(a), I.R.C. 1986. Net bond proceeds will be deposited with lenders pursuant to a lender loan agreement and the lenders will loan the proceeds to hospitals specified by P under terms specified by P. The lender loan agreement gives P firm control over the use of the bond proceeds.
Read the full summary
P proposes to issue bonds pursuant to an indenture between P and a corporate trustee and seeks a declaratory judgment that such bonds would be described in sec. 103(a), I.R.C. 1986. Net bond proceeds will be deposited with lenders pursuant to a lender loan agreement and the lenders will loan the proceeds to hospitals specified by P under terms specified by P. The lender loan agreement gives P firm control over the use of the bond proceeds. At least 95 percent of the net bond proceeds will be used for the exempt purpose of "hospitals" as that term is used in sec. 145(b) and will not be used in…
1Opinion of the Court
California Health Facilities Authority, Petitioner v. Commissioner of Internal Revenue, Respondent
California Health Facilities Authority v. Commissioner
Docket No. 6577-85B
United States Tax Court
90 T.C. 832; 1988 U.S. Tax Ct. LEXIS 56; 90 T.C. No. 56;
May 2, 1988; As amended May 11, 1988 May 2, 1988, Filed
Decision will be entered for the petitioner.
P proposes to issue bonds pursuant to an indenture between P and a corporate trustee and seeks a declaratory judgment that such bonds would be described in sec. 103(a), I.R.C. 1986. Net bond proceeds will be deposited with lenders pursuant to a…
2Cases cited1 opinion
- California Health Facilities Authority v. CommissionerUnited States Tax Court · 1988