Federal Home Loan Mortgage Corporation - Page 5

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          At various points in the taxable years 1985 and 1986, petitioner            
          foreclosed on these mortgages and obtained freehold title to the            
          underlying real estate.  Petitioner was required to demonstrate             
          its gain or loss on the foreclosures.                                       
               For the taxable years 1985 through 1990, petitioner                    
          consistently accrued into income stated interest on all single-             
          family mortgages that it owned, whether or not that interest was            
          received.  If such a mortgage was or became delinquent,                     
          petitioner nonetheless continued to accrue the interest through             
          the date of foreclosure.  Petitioner accrued into income interest           
          from the date of acquisition through the date of foreclosure in             
          respect of all mortgages acquired before January 1, 1985, that              
          were subject to foreclosure after that date.4                               
               As part of the legislation in which petitioner became                  
          subject to Federal income taxation, Congress enacted transition             
          rules for determining petitioner’s adjusted basis in assets that            
          it held on January 1, 1985.  Those rules are contained in DEFRA             
          section 177(d), 98 Stat. 711, which 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--                                               



               4Petitioner’s treatment of interest accrued after Jan. 1,              
          1985, is not in dispute.                                                    





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