City of Columbus , Ohio - Page 3

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          reflecting such an intent", we should conclude that, without such           
          technical amendment, the language in the body of the General                
          Explanation ought not to be taken into account.  We were of the             
          view, however, that petitioner's argument was far too speculative           
          to merit consideration and consequently saw no need to refer to             
          the language in the body of the General Explanation or the                  
          footnote because other materials which we discussed in our prior            
          opinion furnished more than an adequate foundation for our                  
               In its motion for reconsideration, petitioner sets forth its           
          new discovery, namely that Congress in enacting the Technical and           
          Miscellaneous Revenue Act of 1988 (TAMRA 1988), Pub. L. 100-647,            
          sec. 1013(d), 102 Stat. 3342, 3548, included the following                  
          addition as section 1314(h) of the Tax Reform Act of 1986:                  
                    (h)  Arbitrage Restriction on Investments in                      
               Investment-Type Property.--In the case of a bond issued                
               before August 16, 1986 (September 1, 1986 in the case                  
               of a bond described in section 1312(c)(2)), section                    
               103(c) of the 1954 Code shall be applied by treating                   
               the reference to securities in paragraph (2) thereof as                
               including a reference to investment-type property but                  
               only for purposes of determining whether any bond                      
               issued after October 16, 1987, to advance refund such                  
               bond (or a bond which is part of a series of refundings                
               of such bond) is an arbitrage bond (within the meaning                 
               of section 148(a) of the 1986 Code).                                   
               Petitioner asserts that this provision requires us to                  
          determine the tax-exempt status of the bond issue involved herein           
          under the 1954 Code and not the 1986 Code, which came into being            

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