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Taxable Year Amortization Deduction
1985 $50,219,116
1986 48,702,457
1987 47,017,000
1988 45,835,556
1989 40,680,420
1990 38,028,084
In this Opinion, we decide whether the benefit of
petitioner’s favorable financing can, as a matter of law,
constitute an intangible asset for tax purposes.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing the
petition, petitioner’s principal office was located in McLean,
Virginia. At all relevant times, petitioner was a corporation
managed by a board of directors.
Petitioner was chartered by Congress on July 24, 1970, by
the Emergency Home Financing Act of 1970, Pub. L. 91-351, title
III (Federal Home Loan Mortgage Corporation Act), 84 Stat. 451.
Petitioner was originally exempt from Federal income taxation.
However, Congress repealed petitioner’s Federal income tax
exemption status in the Deficit Reduction Act of 1984 (DEFRA),
Pub. L. 98-369, sec. 177, 98 Stat. 709. Pursuant to this Act,
petitioner became subject to Federal income taxation, effective
January 1, 1985.
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