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CITY OF NEW YORK v. COMMISSIONER

Docket No. 27960-92B.

103 T.C. 481 (1994)

CITY OF NEW YORK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 11, 1994.

Attorney(s) appearing for the Case

James S. Kaplan, Helene Jaffa, Robert Firestone, and Amy F. Nogid, for petitioner.

Marsha A. Keyes, Rebecca L. Caldwell-Harrigal, and Richard L. Carlisle, for respondent.

OPINION

HAMBLEN, Chief Judge:

This is an action for declaratory judgment pursuant to section 7478.1 Petitioner requested respondent to rule that general obligation bonds (bonds) in the face amount of $100 million that petitioner proposes to issue will be obligations described in section 103(a), so that the interest thereon will be excludable from the bondholders' gross income. After administrative review, respondent denied...

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