ATLANTA - If Brevard County, Fla., voters opt to cease making lease appropriations on an insured certificates of participation issue in an upcoming referendum, interest payments could be declared taxable, a 1988 Internal Revenue Service private-letter ruling suggests, tax lawyers said yesterday.

In particular, the lawyers said a paragraph near the end of the private-letter ruling issued, which came in response to an unnamed issuer's questions, could spell trouble for holders of the $23.9 million Brevard County financing.

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