Federal Home Loan Mortgage Corporation - Page 11

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               The terms of each GMC series obligated petitioner to pay               
          interest at a rate stated on the face of its prospectus and to              
          repay the face amount of the certificate to the holder.                     
          Principal payments were made annually.  GMC holders received                
          principal repayments in amounts equal to the greater of (1)                 
          minimum scheduled payments, or (2) monthly and other payments of            
          principal petitioner received on the mortgages serving as                   
          collateral.  Petitioner was unconditionally required to make                
          annual principal payments to the GMC holders in an amount at                
          least equal to the minimum levels specified, regardless of the              
          amounts of principal received from the underlying mortgages.  If            
          mortgages that served as collateral paid down the principal                 
          amount faster than implied by the schedules of minimum payments,            
          GMC holders received payments of principal at a faster rate than            
          required by the schedule of minimum payments.  GMCs holders had             
          the option to require petitioner to purchase their certificates             

               7(...continued)                                                        
               interests in the Mortgages, the terms of the                           
               Certificates are such that for Federal income tax                      
               purposes * * * [petitioner] will not be selling                        
               undivided interests in the Mortgages but will be                       
               issuing debt obligations for which the Mortgages held                  
               by the Trustee are security.  * * *                                    
                                                                                     
          On May 13, 1983, respondent revoked this private letter ruling              
          and related rulings.  See Priv. Ltr. Rul. 8337016 (May 23, 1983).           
          Respondent does not presently regard GMCs as debt for tax                   
          purposes; however, under the provisions of sec. 7805(b),                    
          respondent has permitted petitioner to treat its GMCs issued                
          before May 23, 1983, including all of the GMCs at issue in this             
          case, as debt for tax purposes.                                             




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