Federal Home Loan Mortgage Corporation - Page 2

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               the deduction allowable under this paragraph, but only                 
               if it has previously been returned as income.”  P’s                    
               accrued interest, which was accrued when P was tax                     
               exempt and not required to file income tax returns, was                
               not “returned as income” within the meaning of sec.                    
               1.166-6(a)(2), Income Tax Regs., and P is not entitled                 
               to increase its regular adjusted cost basis for these                  
               amounts.                                                               


               Robert A. Rudnick, Stephen J. Marzen, James F. Warren, and             
          Neil H. Koslowe, for petitioner.                                            
               Gary D. Kallevang, for respondent.                                     


                                       OPINION                                        

               RUWE, Judge:  Respondent determined deficiencies in                    
          petitioner’s Federal income taxes in docket No. 3941-99 for 1985            
          and 1986, as follows:                                                       
                    Year                          Deficiency                          
                    1985                     $36,623,695                              
                    1986                          40,111,127                          
          Petitioner claims overpayments of $9,604,085 for 1985 and                   
          $12,418,469 for 1986.                                                       
               Respondent determined deficiencies in petitioner’s Federal             
          income taxes in docket No. 15626-99 for 1987, 1988, 1989, and               
          1990, as follows:                                                           










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