- 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.
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