Legal Opinion

City of Columbus v. Commissioner

United States Tax Court

Decided May 14, 1996No. Docket No. 3301-95BPublished

P, a home rule municipal corporation and political subdivision of the State of Ohio, seeks a declaratory judgment that interest on bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. In 1967, in exchange for the assumption of P's accrued unfunded pension obligation by a fund established for that purpose by the State of Ohio, P incurred a long-term obligation to the State Fund.

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P, a home rule municipal corporation and political subdivision of the State of Ohio, seeks a declaratory judgment that interest on bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. In 1967, in exchange for the assumption of P's accrued unfunded pension obligation by a fund established for that purpose by the State of Ohio, P incurred a long-term obligation to the State Fund. In 1994, P made a lump-sum payment equal to 65 percent of the remaining principal in satisfaction of the long-term obligation. Taking into account the 35-percent discount, the yield to P in…

1Opinion of the Court

CITY OF COLUMBUS, OHIO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

City of Columbus v. Commissioner

Docket No. 3301-95B

United States Tax Court

106 T.C. 325; 1996 U.S. Tax Ct. LEXIS 18; 106 T.C. No. 17;

May 14, 1996, Filed

Decision will be entered for respondent.

P, a home rule municipal corporation and political subdivision of the State of Ohio, seeks a declaratory judgment that interest on bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. In 1967, in exchange for the assumption of P's accrued unfunded pension obligation by a fund established for that…

2Cases cited4 opinions

  1. Woodward v. CommissionerSupreme Court of the United States · 1970
  2. Santa Fe Pacific Corporation v. Central States, Southeast and Southwest Areas Pension FundCourt of Appeals for the Seventh Circuit · 1994
  3. Coca-Cola Co. v. CommissionerUnited States Tax Court · 1996
  4. City of Columbus v. CommissionerUnited States Tax Court · 1996

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