Federal Home Loan Mortgage Corporation - Page 13

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          legislative history indicates that Congress wanted to extend this           
          type of deduction to expenditures that were incurred during a               
          year when the taxpayer was already exempt from income tax.                  
               We hold that petitioner is not entitled to the claimed                 
          amortization deductions under section 177(a).                               


                                                  An appropriate order                
                                             will be issued.                          
































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