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CITY OF SANTA ROSA, CAL. v. COMMISSIONER

Docket No. 7310-00B.

120 T.C. 339 (2003)

120 T.C. No. 12

CITY OF SANTA ROSA, CALIFORNIA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 13, 2003.

Attorney(s) appearing for the Case

David L. Miller and David A. Walton, for petitioner.

Gary W. Bornholdt and Timothy L. Jones, for respondent.

OPINION

RUWE, Judge:

This is an action for declaratory judgment pursuant to section 7478.1 Petitioner requested a ruling from respondent that interest on bonds it proposes to issue will be excludable from gross income under section 103(a), and that the proposed bonds will not be private activity bonds within the meaning of section 141(a). Respondent determined that the proposed bonds will constitute private activity bonds...

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