- 6 -
assets held by petitioner on January 1, 1985. DEFRA section
177(d)(2)(A) provides:
(2) Adjusted basis of assets.--
(A) In general.--Except as otherwise provided in
subparagraph (B), the adjusted basis of any asset of
the Federal Home Loan Mortgage Corporation held on
January 1, 1985, shall--
(i) for purposes of determining any loss, be equal
to the lesser of the adjusted basis of such asset or
the fair market value of such asset as of such date,
and
(ii) for purposes of determining any gain, be
equal to the higher of the adjusted basis of such asset
or the fair market value of such asset as of such date.
[Emphasis added.]
Petitioner claims that it is entitled to amortize
intangibles that it held on January 1, 1985, using a fair market
value basis under DEFRA section 177(d)(2)(A)(ii). Petitioner
claims the following fair market values for its alleged
intangibles:
Intangibles Fair Market Value
Information systems $27,214,000
Favorable leasehold 9,459,349
Seller/servicer list 6,215,000
Favorable financing 456,021,853
Customer relations 600,000,000
Petitioner claims entitlement to the following amortization
deductions for its 1985-90 taxable years:
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011