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established that its favorable financing intangible assets have
fair market values that may be reasonably estimated and have
ascertainable limited useful lives as of January 1, 1985.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of facts and the attached exhibits are
incorporated herein by this reference. At the time the petitions
were filed, petitioner’s principal office was in McLean,
Virginia.
Congress created petitioner in 1970 to promote access to
mortgage credit throughout the United States by increasing the
liquidity of mortgage investments and improving the distribution
of investment capital for mortgage financing. Since its
incorporation, petitioner has facilitated investment by the
capital markets in single-family and multifamily residential
mortgages in two ways. First, petitioner has acquired mortgages
from originators and resold them in securitization transactions,
principally by pooling the mortgages and issuing participation
certificates (PCs). Second, petitioner bought mortgages from
originators and held them until maturity in its retained mortgage
portfolio, generally financing this activity by issuing various
2 This issue is one of several involved in these cases. See
Fed. Home Loan Mortgage Corp. v. Commissioner, 125 T.C. 248
(2005); 121 T.C. 129 (2003); 121 T.C. 254 (2003); 121 T.C. 279
(2003); T.C. Memo. 2003-298.
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