Legal Opinion
City of New York v. Commissioner of Internal Revenue
Court of Appeals for the D.C. Circuit
Decided November 28, 1995No. 94-1739PublishedCited by 20 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge SILBERMAN.
SILBERMAN, Circuit Judge:
The City of New York appeals from a decision of the Tax Court rejecting its request for a declaratory judgment that the interest paid on general obligation bonds that the city seeks to issue will be exempt from taxation. We affirm.
I
The interest paid on bonds issued by municipalities is, with a few exceptions, excluded from taxable income. 26 U.S.C. § 103(a) (1988). The exception relevant here restricts the use of bond proceeds to finance “private activity.” 26 U.S.C. § 103(b)(1). Under § 141(e), a bond is a…
2Cases cited6 opinions
- Lujan v. Defenders of WildlifeSupreme Court of the United States · 1992
- Maryland Casualty Co. v. Pacific Coal & Oil Co.Supreme Court of the United States · 1941
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Humes v. United StatesSupreme Court of the United States · 1928
- United States v. Wells Fargo BankSupreme Court of the United States · 1988
1 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- ASAT, Inc. v. CommissionerUnited States Tax Court · 1997
- Anderson v. Comm'rUnited States Tax Court · 2004
- Intel Corp. & Consol. Subsidiaries v. CommissionerUnited States Tax Court · 1998
- Warbelow's Air Ventures v. Comm'rUnited States Tax Court · 2002
15 more not listed; retrieve them via the Exa API.