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CONTINENTAL BANK v. UNITED STATES

Civ. A. No. 78-2527.

517 F.Supp. 918 (1981)

CONTINENTAL BANK v. UNITED STATES of America.

United States District Court, E. D. Pennsylvania.

May 27, 1981.

Attorney(s) appearing for the Case

David H. Pittinsky, Philadelphia, Pa., for plaintiff.

Francis G. Hertz, Tax Division, Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM AND ORDER

FULLAM, District Judge.

Section 103 of the Internal Revenue Code, 26 U.S.C. § 103, excludes from taxation as income, interest earned on obligations of states and municipalities; removes from this exemption interest earned on, inter alia, industrial development bonds; exempts from the latter exception certain "small issues" of industrial development bonds aggregating $1 million or less; and, finally, permits an increase of...

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