State Bank of Albany v. United States

This is an appeal from a judgment dismissing an action to recover income taxes paid for the year 1962. The taxpayer, State Bank of Albany, contended in the court below that interest on student loans paid to it by the New York Higher Education Assistance Corporation was exempt from income taxation as “interest on * * * the obligations of a State * * * or any political subdivision” under Section 103(a) (1) of the Internal Revenue Code of 1954, 26 U.S.C. § 103 (a) (1) (1964). The district court, in an opinion reported at 276 F.Supp. 744 (N.D.N.Y.1967), held that the interest was not exempt from…