Internal Revenue Service
Revenue Ruling

TaxLinks.com   sm

 Rev. Rul. 76-11

1976-1 C.B. 30

Section 103

IRS Headnote

Industrial development bonds; monorail transit system. A city's proposed monorail rapid transit system that will provide daily passenger service for tourists commuting between an airport, hotels, tourist attractions, and a convention center, and also be available for use by the general public, will constitute "mass commuting facilities" to the extent defined in section 1.103-8(e)(2)(iii) of the regulations.

Full Text

Rev. Rul. 76-11

A city proposes to issue industrial development bonds to finance the acquisition and construction of a rapid transit system (monorail) that will provide passenger service for commuting between an airport, hotel, tourist attractions, and a convention center along a prescribed route in the city approximately nine miles in length. Passengers will be able to board or leave the system vehicles at various stations along the route. Although tourists will be the primary passengers, the system will be available to all members of the general public at all times. Its use will not be limited to the patrons of the hotels, tourist attractions, or convention center along the route. The system will operate daily and will have the capacity to serve the general public on a mass scale.

Held, in determining whether interest on the bonds to be issued will be exempt, the proposed rapid transit system will constitute "mass commuting facilities" to the extent defined in section 1.103-8(e)(2)(iii) of the Income Tax Regulations.