CAL. HEALTH FACILITIES AUTHORITY v. COMMISSIONER

Docket No. 6577-85B.

90 T.C. 832 (1988)

CALIFORNIA HEALTH FACILITIES AUTHORITY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 2, 1988.


Attorney(s) appearing for the Case

Dean E. Criddle and Greg R. Riddle, for the petitioner.

L. Michael Wachtel, for the respondent.


OPINION

WILLIAMS, Judge:*

The Commissioner determined that certain obligations that petitioner proposes to issue would not be described in section 103(a).1 Petitioner seeks a declaratory judgment of this Court pursuant to section 7478 that the proposed obligations will be described in section 103(a) with the result that interest paid on the obligations would be excludable from a bondholder...

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