Rev. Rul. 56-33

The Indiana Toll Road Commission was created as a body both corporate and politic under Chapter 281 of the Acts of the General Assembly of the State of Indiana of 1951, effective March 7, 1951. The Commission is authorized and empowered to construct, maintain, repair, police, and operate toll road projects (as defined in the Acts) at such locations as shall be approved by the Governor of Indiana and in accordance with such alignment and design standards as shall be approved by the State Highway Commission of Indiana. The Toll Road Commission is further authorized and empowered to acquire public or private lands in the name of the State by purchase or condemnation; to issue toll road revenue bonds, payable solely from revenues, for the purpose of paying all or any part of the cost of any one or more toll road projects; and to fix and revise from time to time, and charge and collect, tolls from transit over each toll road project constructed by it and charges for the use of the facilities thereof. Held, the Indiana Toll Road Commission is a political subdivision of a State within the meaning of sections 103(a)(1) and 4292 of the Internal Revenue Code of 1954. Accordingly, the interest on bonds issued by the Commission is exempt from Federal income tax. See Commissioner v. Estate of Alexander J. Shamberg, 144 Fed. (2d) 998, Ct. D. 1648, C. B. 1945, 335, certiorari denied, 323 U. S. 792, and Commissioner v. Estate of Caroline White, 144 Fed. (2d) 1019, Ct. D. 1647, C. B. 1945, 65, certiorari denied, 323 U. S. 792. Also, amounts paid for the transportation of property to or from that Commission are exempt from the tax on the transportation of property. See Revenue Ruling 55-162, C. B. 1955-1, 541, relating to the exemption of amounts paid for the transportation of construction materials consigned to a state or political subdivision thereof, in care of a contractor, for incorporation into a state project.