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STATE OF WASHINGTON v. COMMISSIONER

Docket No. 16153-79B.

77 T.C. 656 (1981)

STATE OF WASHINGTON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 24, 1981.

Attorney(s) appearing for the Case

C. Willis Ritter and Walter D. Haynes, for the petitioner.

Charles W. Rumph and Elizabeth D. DePriest, for the respondent.

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...

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