- 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