Federal Home Loan Mortgage Corporation - Page 3

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                    Year                          Deficiency                          
                    1987                         $26,200,358                          
                    1988                          13,827,654                          
                    1989                          6,225,404                           
                    1990                          23,466,338                          
          Petitioner claims overpayments of $57,775,538 for 1987,                     
          $28,434,990 for 1988, $32,577,346 for 1989, and $19,504,333 for             
          1990.                                                                       
               Petitioner and respondent filed cross-motions for partial              
          summary judgment under Rule 1211 on the question of whether                 
          petitioner is entitled to amortize the economic benefit of                  
          certain debt obligations which had below-market interest rates on           
          January 1, 1985, the date petitioner became subject to Federal              
          income taxation.  Petitioner claims entitlement to amortize its             
          favorable financing using a fair market value basis as of that              
          date.  Petitioner determined the fair market value of the claimed           
          favorable financing to total $456,021,853 on January 1, 1985, and           
          claims the following amortization deductions for taxable years              
          1985 through 1990:                                                          








               1All Rule references are to the Tax Court Rules of Practice            
          and Procedure, and all section references are to the Internal               
          Revenue Code in effect for the taxable years in issue, unless               
          otherwise indicated.                                                        




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