[Code of Federal Regulations]
[Title 26, Volume 2]
[Revised as of April 1, 2003]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.150-1A]

[Page 737-738]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1--INCOME TAXES--Table of Contents
 
Sec. 1.150-1A  Definitions.

    (a) through (b) [Reserved]. For guidance see Sec. 1.150-1.
    (c) Definition of issue--(1) In general. Except as otherwise 
provided, the provisions of this paragraph (c) apply for all purposes of 
sections 103 and 141 through 150. Except as otherwise provided in this 
paragraph (c), two or more bonds are treated as part of the same issue 
if all of the following factors are present:
    (i) Sold at substantially the same time. The bonds are sold at 
substantially the same time. Bonds are treated as sold at substantially 
the same time if they are sold less than 15 days apart. For this purpose 
only, a variable yield bond is treated as sold on its issue date.
    (ii) Sold pursuant to the same plan of financing. The bonds are sold 
pursuant to the same plan of financing. Factors material to the plan of 
financing include the purposes for the bonds and the structure of the 
financing. For example, generally--
    (A) Bonds to finance a single facility or related facilities are 
part of the same plan of financing;
    (B) Short-term bonds to finance working capital expenditures and 
long-term bonds to finance capital projects are not part of the same 
plan of financing; and
    (C) Certificates of participation in a lease and general obligation 
bonds secured by tax revenues are not part of the same plan of 
financing.
    (iii) Payable from same source of funds. The bonds are reasonably 
expected to be paid from substantially the same source of funds, 
determined without regard to guarantees from parties unrelated to the 
obligor.
    (2) through (4)(ii) [Reserved]. For guidance see Sec. 1.150-1 (c)(3) 
through (c)(4)(ii).
    (c)(4)(iii) Certain general obligation bonds. Bonds are part of the 
same issue if secured by a pledge of the issuer's full faith and credit 
(or a substantially similar pledge) and sold and issued on the same 
dates pursuant to a single offering document.
    (5) [Reserved]. For guidance see Sec. 1.150-1(c)(5).
    (6) Sale date. The sale date of a bond is the first day on which 
there is a binding contract in writing for the sale or exchange of the 
bond.

[T.D. 8538, 59 FR 24046, May 10, 1994. Redesignated by T.D. 8718, 62 FR 
25513, May 9, 1997]

[[Page 738]]

                   Deductions for Personal Exemptions