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HARBOR BANCORP & SUBSIDIARIES v. C.I.R.

No. 96-70037.

115 F.3d 722 (1997)

HARBOR BANCORP & SUBSIDIARIES; Edward J. Keith; Elena Keith, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 10, 1997.

As Amended August 6, 1997.

Attorney(s) appearing for the Case

Mary Gassmann Reichert, Bryan Cave, St. Louis, Missouri, for petitioners-appellants.

Richard Farber (argued), Gary R. Allen, Edward T. Perelmuter, Tax Division, United States Department of Justice, Washington, D.C., for respondent-appellee.

Before MAGILL, RYMER, and THOMAS, Circuit Judges.

OPINION

RYMER, Circuit Judge:

Taxpayers Harbor Bancorp and Edward and Elena Keith appeal from a decision of the Tax Court denying tax-exempt status to interest the taxpayers earned on bonds issued by the Riverside County, California, Housing Authority. The Tax Court determined that (1) the Riverside County bond issues were subject to the Tax Reform Act of 1986 because the bonds were issued after December 31...

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