WASHINGTON -- A private, nonprofit college does not have to count student loan bonds issued before 1986 toward the $150 million limit on the tax-exempt 501(c)(3) bonds it may have outstanding, the Internal Revenue Service has ruled.

The private letter ruling, which was published by the IRS last week without identifying the parties involved, takes a broad view on the amount of tax-exempt bonds that private colleges may have outstanding standing by relying on the intent Congress used in writing the Tax Reform Act of 1986, rathen than on the actual language of the law, several lawyers said this week.

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