Washington v. Commissioner
United States Tax Court
Petitioner seeks a declaratory judgment that bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. 1954, and not arbitrage bonds as defined in sec. 103(c). Petitioner intends to invest the proceeds from these bonds in U.S.
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Petitioner seeks a declaratory judgment that bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. 1954, and not arbitrage bonds as defined in sec. 103(c). Petitioner intends to invest the proceeds from these bonds in U.S. Government securities which offer a yield to petitioner not in excess of the yield which its bonds will produce, but only if the yield on petitioner's bonds is computed by taking into account petitioner's issuing expenses including underwriter's spread. Held, petitioner's method of computing the "yield" on its proposed bonds is sustained. Held,…
1Opinion of the Court
OPINION
Tannenwald, Chief Judge:
This is an action for a declaratory judgment pursuant to section 7478.1 On March 1, 1979, petitioner submitted a ruling request to respondent following the procedures set forth in Rev. Proc. 79-4, 1979-1 C.B. 483. Petitioner requested respondent to rule that the general obligation refunding bonds it proposed to issue are not "arbitrage bonds” within the meaning of section 103(c) and that the interest paid by petitioner to the holders of such bonds would be exempt from Federal income tax pursuant to section 103(a). After a lengthy administrative review,…
2Cases cited18 opinions
- Alessi v. Raybestos-Manhattan, Inc.Supreme Court of the United States · 1981
- Mourning v. Family Publications Service, Inc.Supreme Court of the United States · 1973
- United States v. CorrellSupreme Court of the United States · 1967
- Brewster v. GageSupreme Court of the United States · 1930
- United States v. CartwrightSupreme Court of the United States · 1973
13 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Miller v. CommissionerUnited States Tax Court · 1985
- Estate of Boeshore v. CommissionerUnited States Tax Court · 1982
- State of Washington v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1982
- Swallows Holding, Ltd. v. Comm'rUnited States Tax Court · 2006
- Stephenson Trust v. CommissionerUnited States Tax Court · 1983
37 more not listed; retrieve them via the Exa API.