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interest on the proposed bonds will be excludable from the gross
income of prospective bondholders under section 103(a).
Background
This case was submitted fully stipulated under Rule 122.
The stipulation of facts, the stipulation as to administrative
record, and the attached exhibits are incorporated herein by this
reference.
Petitioner is a political subdivision of the State of
California and has taxing powers, police powers, and powers of
eminent domain under the constitution and laws of that State.
Petitioner owns and operates a subregional sewage and water
reclamation system, which includes facilities for collection and
treatment of sewage and other effluent, tertiary treatment of the
wastewater produced therefrom, a reservoir for storing
wastewater, pipelines, and other facilities for the
transportation of wastewater to discharge points.2 This system
serves approximately 250,000 people in central Sonoma County,
California, including the cities of Santa Rosa, Rohnert Park,
Cotati, and Sebastopol, as well as a portion of the
unincorporated area of Sonoma County. As of July 31, 1996, the
system had a capacity for 18 million gallons of wastewater per
day, which was disposed of by means of urban irrigation, created
2Wastewater or effluent generated by petitioner’s sewage
treatment process receives tertiary treatment under California
Department of Health Services standards before any discharge.
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Last modified: May 25, 2011