Federal Home Loan Mortgage Corporation - Page 14

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          Similarly, in these cases, petitioner seeks to amortize the right           
          to use borrowed money provided for in its various debt                      
          obligations.  The differential between the market rate of                   
          interest and the contract rate of interest serves as a measure of           
          the economic value of that right as of January 1, 1985.  Thus, we           
          cannot agree with respondent’s attempt to analyze petitioner’s              
          right to use borrowed money separately from the comparable cost             
          of that use.  For the reasons discussed above and in Dickman v.             
          Commissioner, 465 U.S. 330 (1984), the right to use borrowed                
          money is interrelated with the corresponding interest cost of               
          that right, in much the same way that the right to use property             
          is interrelated with its corresponding rental cost.                         
               Petitioner’s interest in its favorable financing is in many            
          respects analogous to a bank’s interest in its “deposit base” or            
          “core deposits”, which we have held to be an intangible asset               
          amortizable for tax purposes.  “The term ‘deposit base’ describes           
          ‘the intangible asset that arises in a purchase transaction                 
          representing the present value of the future stream of income to            
          be derived from employing the purchased core deposits of a                  
          bank.’”  Newark Morning Ledger Co. v. United States, 507 U.S. at            
          561 n.11 (quoting Citizens & S. Corp. v. Commissioner, 91 T.C.              
          463, 465 (1988), affd. 919 F.2d 1492 (11th Cir. 1990)).  “The               
          value of the deposit base rests upon the ‘ascertainable                     
          probability that inertia will cause depositors to leave their               






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