City of Santa Rosa v. Comm'r
United States Tax Court
P petitions this Court pursuant to sec. 7478, I.R.C., seeking a declaration that interest on certain bonds will be exempt from taxation under sec. 103(a), I.R.C. P proposes to issue bonds of $ 140 million to finance the construction of a pipeline. The pipeline will dispose of wastewater generated in P's subregional sewage and water reclamation system.
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P petitions this Court pursuant to sec. 7478, I.R.C., seeking a declaration that interest on certain bonds will be exempt from taxation under sec. 103(a), I.R.C. P proposes to issue bonds of $ 140 million to finance the construction of a pipeline. The pipeline will dispose of wastewater generated in P's subregional sewage and water reclamation system. P has entered into an agreement obligating P to deliver, and a utility company to accept, an average of 11 million gallons of wastewater per day. The utility company will use the wastewater to activate geysers and produce steam for the…
1Opinion of the Court
OPINION
Ruwe, Judge:
This is an action for declaratory judgment pursuant to section 7478.1 Petitioner requested a ruling from respondent that interest on bonds it proposes to issue will be excludable from gross income under section 103(a), and that the proposed bonds will not be private activity bonds within the meaning of section 141(a). Respondent determined that the proposed bonds will constitute private activity bonds, and any interest on the proposed bonds will not be excludable from gross income under section 103(a). The issue for decision is whether interest on the proposed bonds will be…
2Cases cited2 opinions
- City of New York v. CommissionerUnited States Tax Court · 1994
- City of New York v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1995
3Cited by2 opinions
- City of Santa Rosa v. Comm'rUnited States Tax Court · 2003
- City of Santa Rosa, California v. CommissionerUnited States Tax Court · 2003