Two fees paid by a borrower for credit enhancement and a mortgage on a solid-waste disposal facility will not be considered issuance costs for purposes of determining if the bonds issued to finance the facility are tax-exempt qualified private-activity bonds, the Internal Revenue Service ruled recently.

The IRS detailed its ruling on the facility in a private-letter ruling that was publicly released earlier this month. The ruling, dated Nov. 20, did not identify the bonds or the issuer. Private-letter rulings, while technically applicable only to the issuer that requested them, are seen as important guidance on the IRS' thinking on tax matters.

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