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Respondent also focuses on the magnitude of the amortization
deductions that petitioner claims for 1985 through 1990. Those
deductions range from approximately $99 million in 1990 to $117.8
million in 1985. Respondent claims that allowing deductions of
this size would be inconsistent with Congress’s repeal of
petitioner’s tax exempt status, since it virtually eliminates
petitioner’s tax liabilities for the years following January 1,
1985.18 Respondent relies upon certain revenue estimates
contained in Staff of Joint Comm. on Taxation, General
Explanation of the Revenue Provisions of the Deficit Reduction
Act of 1984, at 555 (J. Comm. Print 1984), as follows: “This
provision is estimated to increase fiscal year budget receipts by
$67 million in 1985, $109 million in 1986, $142 million in 1987,
$185 million in 1988, and $240 million in 1989.” Respondent
speculates that given the size of the amortization deductions,
petitioner’s tax liabilities for 1985-90 would fall substantially
short of the revenue estimates.
First, we fail to see how the revenue estimates and the
comparative reductions in petitioner’s tax liabilities are
particularly relevant to the question before us, which involves
18Respondent contends that allowing deductions of this size
would have allowed petitioner to maintain its competitive
advantage against its chief competitor, the Federal National
Mortgage Association (Fannie Mae), a consequence which Congress
sought to avoid. See Staff of Joint Comm. on Taxation, General
Explanation of the Revenue Provisions of the Deficit Reduction
Act of 1984, at 550 (J. Comm. Print 1984).
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