106 T.C. No. 17 UNITED STATES TAX COURT CITY OF COLUMBUS, OHIO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3301-95B. Filed May 14, 1996. P, a home rule municipal corporation and political subdivision of the State of Ohio, seeks a declaratory judgment that interest on bonds it proposes to issue will be exempt from taxation under sec. 103(a), I.R.C. In 1967, in exchange for the assumption of P's accrued unfunded pension obligation by a fund established for that purpose by the State of Ohio, P incurred a long- term obligation to the State Fund. In 1994, P made a lump-sum payment equal to 65 percent of the remaining principal in satisfaction of the long-term obligation. Taking into account the 35-percent discount, the yield to P in making the prepayment, as compared to the payments it otherwise would have made, is 7.57484 percent. P proposes to issue long-term obligations, with an interest rate of 6 percent, to fund the prepayment to the State Fund. Pending our decision herein, P has issued short-term obligations to fund the prepayment. Held, P entered into the prepayment transaction with a principal purpose being to profitPage: 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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