- 2 - to sec. 148(f), I.R.C., and that, as a result, the interest on the bonds was not excludable from Ps' income. Held: The Commissioner's determination is upheld. The bonds are to be treated as arbitrage bonds pursuant to sec. 148(f), I.R.C. The interest on the bonds is not excludable from Ps' taxable income under sec. 103(a), I.R.C. Anita C. Esslinger, Mary Gassmann Reichert, Brenda J. Talent, Juan D. Keller, Michael F. Coles, and Linda M. Martinez (specially recognized), for petitioner in docket No. 24112-92. Mary Gassmann Reichert, Juan D. Keller, Michael F. Coles, and Linda M. Martinez (specially recognized), for petitioners in docket No. 5857-93. Clifton B. Cates III, Lillian D. Brigman, Debra Lynn Reale, and Jon Kent, for respondent. RUWE, Judge:* Respondent determined the following deficiencies in petitioners' Federal income taxes: Harbor Bancorp & Subsidiaries docket No. 24112-92 Year Deficiency 1988 $6,587 1989 6,588 1990 6,588 *This case was reassigned to Judge Robert P. Ruwe by order of the Chief Judge.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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