WASHINGTON – The issuance of new bonds is a refunding, notwithstanding the technical termination of a partnership within six months, the Internal Revenue Service concluded in a recent private-letter ruling.

The favorable letter ruling was dated March 28 but was not made available to the public until late last week by the IRS chief counsel’s office. Timothy Jones, senior counsel, signed the letter, which did not identify the issuer, borrower, banks or third parties that were associated with the transactions and partnerships in the deal.

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