Legal Opinion

Harbor Bancorp v. Commissioner

United States Tax Court

Decided October 16, 1995No. Docket Nos. 24112-92, 5857-93Published

The Housing Authority of Riverside County, California, issued revenue bonds to finance the construction of multifamily housing for families of low and moderate incomes. Ps purchased some of these bonds and, believing that the bonds were tax exempt, did not include the interest received thereon in income. Sec. 103(a), I.R.C., generally provides a tax exemption for interest earned on bonds issued by State and local governments.

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The Housing Authority of Riverside County, California, issued revenue bonds to finance the construction of multifamily housing for families of low and moderate incomes. Ps purchased some of these bonds and, believing that the bonds were tax exempt, did not include the interest received thereon in income. Sec. 103(a), I.R.C., generally provides a tax exemption for interest earned on bonds issued by State and local governments. This exemption does not apply to "arbitrage bonds". Sec. 103(c), I.R.C. Under sec. 148(f), I.R.C., a bond is treated as an "arbitrage bond" if (1) the bond proceeds are…

1Opinion of the Court

HARBOR BANCORP & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; EDWARD J. KEITH AND ELENA KEITH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Harbor Bancorp v. Commissioner

Docket Nos. 24112-92, 5857-93.

United States Tax Court

105 T.C. 260; 1995 U.S. Tax Ct. LEXIS 55; 105 T.C. No. 19;

October 16, 1995, Filed

Decisions will be entered for respondent.

The Housing Authority of Riverside County, California, issued revenue bonds to finance the construction of multifamily housing for families of low and moderate incomes. Ps purchased some of these bonds and,…

Also in this document: Concurrence · Swift; Concurrence · Halpern; Concurrence · Beghe; Dissent.

2Cases cited19 opinions

  1. Commissioner v. TowerSupreme Court of the United States · 1946
  2. BFP v. Resolution Trust CorporationSupreme Court of the United States · 1994
  3. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  4. Commissioner v. SchleierSupreme Court of the United States · 1995
  5. Hubbard v. United StatesSupreme Court of the United States · 1995

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