Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 88

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          was indistinguishable from the Government of Great Britain.  Id.            
          at 290-291.                                                                 
               In State of Michigan v. United States, 40 F.3d 817 (6th Cir.           
          1994), the question was whether the investment income of the                
          Michigan Education Trust was exempt from Federal income tax under           
          section 115(i) which provided that "gross income does not include           
          income derived from any public utility or the exercise of any               
          essential governmental functions and accruing to a State or any             
          political subdivision thereof".  The trust was a public "quasi-             
          corporation" established to help parents provide for their                  
          children's college education by receiving and investing advance             
          payments.  The trust had a board of directors which was                     
          authorized to enter into contracts on behalf of the State; the              
          State treasurer was an ex officio member of the board whose                 
          members were appointed by the governor and confirmed by the                 
          Michigan senate; the trust was "within" the treasury department,            
          although it acted independently; assets of the trust were not               
          considered State money, common cash, or State revenue although              
          such assets could be pooled with pension funds and other                    
          investments of the State and invested by State employees; the               
          Michigan auditor general was responsible for auditing the books             
          of the trust and the trust was required to submit annual reports            
          to the governor and the State legislature.  Finding that the                
          provision of education was an essential State function, and after           
          analyzing all the facts and circumstances, the Court of Appeals             




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