- 3 - Edward J. and Elena Keith docket No. 5857-93 Year Deficiency 1989 $14,709 1990 18,521 1991 14,840 These consolidated cases are test cases that involve the Commissioner's attempt to tax interest received on two multifamily housing revenue bonds (the Bonds) issued by the Housing Authority of the County of Riverside, California (the Housing Authority). The ultimate issue for decision is whether interest on the Bonds is excludable from gross income under section 103(a). This, in turn, will depend on the applicability of section 148(f). References to section 103 are to that section of the Internal Revenue Code of 1954,1 as amended, and references to section 148 are to that section of the Internal Revenue Code of 1986.2 Some of the facts have been stipulated and are found accordingly. The stipulations of fact and attached exhibits are 1We apply sec. 103 of the 1954 Code as in effect for Feb. 20, 1986, instead of the 1986 Code, because (1) sec. 1301 of the Tax Reform Act of 1986 (TRA), Pub. L. 99-514, 100 Stat. 2085, 2602, which amended sec. 103, became effective for bonds issued after Aug. 15, 1986, TRA sec. 1311(a), 100 Stat. 2659, and (2) the bonds we deal with were issued before that date. 2We apply sec. 148(f) of the 1986 Code, because (1) TRA sec. 1314(d)(1), 100 Stat. 2664, provides that sec. 103 of the 1954 Code shall be treated as including the requirements of sec. 148(f) of the 1986 Code for bonds issued after Dec. 31, 1985, and (2) we conclude, infra, that the bonds we deal with were issued after that date.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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