Federal Home Loan Mortgage Corporation - Page 4

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               In this opinion, we decide whether, for purposes of                    
          computing a deduction for amortization, the adjusted basis of any           
          amortizable intangible assets that petitioner held on January 1,            
          1985, is the regular adjusted cost basis provided in section 1011           
          or the higher of the regular adjusted cost basis or fair market             
          value of such assets on January 1, 1985, as provided in the                 
          Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-369, sec. 177,            
          98 Stat. 709.                                                               
                                     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          However, Congress repealed petitioner’s Federal income tax                  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 DEFRA section 177.  Pursuant to this Act,               
          petitioner became subject to Federal income taxation, effective             
          January 1, 1985.                                                            








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