- 10 - 37 B.T.A. 249 (1938); Standard Inv. Co. v. Commissioner, 36 B.T.A. 156 (1937). In Riverview State Bank v. Commissioner, 1 T.C. 1147 (1943), following the rationale of the decision of the U.S. Court of Appeals for the Ninth Circuit in Bryant v. Commissioner, supra, we ended much of the controversy surrounding special assessment obligations by holding that the distinction in name only between special assessment bills and special assessment bonds had no bearing on the exclusion. Riverview State Bank v. Commissioner, supra at 1150. In 1952, the Secretary deleted from the regulations the above-quoted language that had been added in Regulations 86 in 1935. See T.D. 5875, 1952-1 C.B. 15. The Treasury Decision noted that it was relieving taxpayers from a limitation in the prior regulations. This deletion was consistent with our decision in Riverview State Bank v. Commissioner, supra, in which we had rejected the drawing of a distinction between special assessment bonds and bills for purposes of the exclusion. In Rev. Rul. 56-159, 1956-1 C.B. 609, the Commissioner, following our decision in Riverview State Bank, took the position that nonrecourse special assessment assignable certificates issued to contractors by a municipality in consideration of paving improvements were the obligations of a political subdivision, and thus exempt from income taxation. The certificates differed in name only from special assessment billsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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