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<br />V"l"ll"j-tt"c;-'x."LIi-J'("x.-l'(-r..-J-l-l("'P]:;"l",i".cj"-J-n"]:;-Ji-LJ- n-:> -/l-v"JJ,,rC:;--;j-r-L-/il" <br /> <br />PLR-116685-99 <br /> <br />4 <br /> <br />under state law. Section 301.7701-1(a) (3) of the Procedural and <br />Administrative Regulations. <br /> <br />City has made a substantial financial commitment to Trust by <br />providing all of its funding. City retains complete control over <br />Trust because it may amend or terminate Trust at any time. City <br />retains control over the daily operation of Trust by its power to <br />appoint or remove agents who manage daily operation. The Trustee <br />is merely a title holder with no power to manage Trust. <br /> <br />CONCLUSION <br /> <br />Provided that City is the only person that makes <br />contributions to Trust, and Trust accepts or holds only amounts <br />of money contributed by City, Trust will be an integral part of <br />City, and any income earned on amounts in Trust will not be <br />subject to federal income tax. <br /> <br />This ruling is directed only to the, taxpayer that requested <br />it. Section 6110 (k) (3) of the Code provides that it may not be <br />used or cited as precedent. <br /> <br />Except as specifically provided otherwise, no opinion is <br />expressed on the federal income tax consequences of the <br />transactior. described above. <br /> <br />In accordance with the terms of a power of attorney on file <br />in this office, a copy of thO letter is being sent to your <br />authorized representative. <br /> <br />Sincerely, <br /> <br />Assistant Chief Counsel <br />(Financial Institutions & Products) <br /> <br />By: William Coppersmith <br />William E. Coppersmith <br />Chief, Branch 2 <br /> <br />16 <br />