- 36 - Conclusion Because the terms and the economic substance of the prior approval purchase contracts indicate that petitioner and originators entered into option contracts, we hold that petitioner properly treated the 0.5-percent nonrefundable portion of the commitment fees as option premiums. To reflect the foregoing, An appropriate order will be issued.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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