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CITY OF NEW YORK v. C.I.R.

No. 94-1739.

70 F.3d 142 (1995)

CITY OF NEW YORK, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided November 28, 1995.

Attorney(s) appearing for the Case

Robert J. Firestone, of Counsel, Corporation Counsel's Office of the City of New York, argued the cause for appellant, with whom Edward F. Hart was on the brief.

Kevin M. Brown, Attorney, United States Department of Justice, argued the cause for appellee, with whom Loretta C. Argrett, Assistant Attorney General, Gary R. Allen and Bruce R. Ellisen, Attorneys, were on the brief.

Before WALD, SILBERMAN and WILLIAMS, Circuit Judges.

Opinion for the Court filed by Circuit Judge SILBERMAN.

SILBERMAN, Circuit Judge:

The City of New York appeals from a decision of the Tax Court rejecting its request for a declaratory judgment that the interest paid on general obligation bonds that the city seeks to issue will be exempt from taxation. We affirm.

I.

The interest paid on bonds issued by municipalities is, with a few exceptions, excluded...

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