Federal Home Loan Mortgage Corporation - Page 6

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                    (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.                
                         *    *    *    *    *    *    *                              
                    (5) Adjusted basis.--For purposes of this                         
               subsection, the adjusted basis of any asset shall be                   
               determined under part II of subchapter O of the                        
               Internal Revenue Code of 1954.                                         
               In computing the gain or loss from its foreclosure sales,              
          petitioner determined its adjusted basis pursuant to DEFRA                  
          section 177(d)(2) for mortgages acquired before, and held on,               
          January 1, 1985.  In determining its adjusted basis under these             
          transition rules, petitioner included in its regular adjusted               
          cost basis the amounts of unpaid interest which it had accrued              
          from the date of acquisition of each mortgage to the date of                
          foreclosure on the underlying real estate.  These amounts of                
          accrued interest included certain interest which had accrued                
          before January 1, 1985.                                                     
               Petitioner used its regular adjusted cost basis in                     
          determining the amount of any gain realized, or loss incurred, on           
          the foreclosure of real estate securing mortgages that petitioner           
          owned on January 1, 1985.  During the taxable year 1985,                    
          petitioner foreclosed on 2,735 mortgages which it had held on               
          January 1, 1985, and petitioner included in its adjusted cost               






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