City of Columbus , Ohio - Page 2

          with that opinion.  Respondent has filed responses thereto as               
          ordered by the Court.                                                       
               The substance of petitioner's motion for reconsideration is            
          our alleged failure to take into account certain legislative                
          history which, according to petitioner, should cause us to reach            
          the opposite conclusion from that articulated in our prior                  
          opinion.  In its reply brief submitted prior to the issuance of             
          that opinion, petitioner, for the first time, argued that its               
          proposed issue was entitled to the benefit of the pre-1986 rules,           
          relying on material in the General Explanation of the Tax Reform            
          Act of 1986 prepared by the staff of the Joint Committee on                 
          Taxation (the General Explanation) in connection with the                   
          enactment of the Tax Reform Act of 1986, Pub. L. 99-514, 100                
          Stat. 2085.  The General Explanation stated with respect to new             
          provisions dealing with arbitrage bonds:                                    
               Congress intended this provision to prohibit issuance                  
               of refunding bonds (as well as new issues) of pension                  
               arbitrage bonds after September 25, 1985, regardless of                
               whether the proceeds of the refunded bonds used to                     
               acquire the annuities may have been treated as spent                   
               proceeds under prior law * * * [Staff of the Joint                     
               Comm. on Taxation, General Explanation of the Tax                      
               Reform Act of 1986, at 1202 (J. Comm. Print 1987);                     
               emphasis added.]                                                       
          To this statement, the following footnote was added:                        
               A technical amendment may be necessary for the statute                 
               to reflect this intent.  [Id. at 1202 n.155; emphasis                  
               In its reply brief, petitioner went on to state that,                  
          because "no subsequent technical amendment * * * was ever enacted           

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