Federal Home Loan Mortgage Corporation - Page 16

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          1985 through 1993, petitioner included taxable income of                    
          $5,636,762, $16,627,101, $2,035,928, $2,601,628, $3,213,184,                
          $3,563,858, $3,569,015, $3,569,015, and $3,569,015, respectively.           
          The adjustments in dispute in the 1985-90 taxable years are the             
          net differences between the amounts of nonrefundable commitment             
          fees received and reported for tax purposes, as follows:                    
          Nonrefundable                                   Amount in                   
           Commitment Fees      Received      Reported    Dispute 1985-90             
          1985           $9,506,398    $5,636,762     $3,869,636                      
          1986           16,489,524    16,627,101       (137,577)                     
          1987            9,408,907     2,035,928      7,372,979                      
          1988            4,525,606     2,601,628      1,923,978                      
          1989            4,892,445     3,213,184      1,679,261                      
          1990            2,805,392     3,563,858       (758,466)                     
               In computing its taxable income for the year 1985,                     
          petitioner overstated its income attributable to such receipts              
          under its method of accounting in the amount of $883,638 as a               
          result of a computational error.                                            
               During the years 1985 through 1988, and 1990, originators              
          failed to deliver at least 67 mortgages specified in prior                  
          approval purchase contracts to petitioner.15  See appendix, which           
          lists these 67 contracts.  As a result, the 1.5-percent                     
          refundable portion of the 2-percent commitment fee was forfeited            
          to petitioner.  During the relevant period, these 67 contracts              


               15 Petitioner was unable to locate records of the prior                
          approval purchase contracts executed in 1989 that would identify            
          the mortgages from that year, if any, where the specified                   
          mortgages were undelivered.                                                 





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