Federal Home Loan Mortgage Corporation - Page 26

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          CMO A-2            99.4511        97.664063    350,000,000                  
          CMO A-3            99.2668        96.390625    435,000,000                  
          CMO C-4            95.6239        94.890625    85,052,100                   
               1  The adjusted issue price is the unpaid principal balance            
          minus the fraction of any unamortized original issue discount               
          remaining as of the valuation date.  For a debt instrument issued           
          at a price that equaled its face value and for which there had              
          been no redemption before Dec. 31, 1984, the adjusted issue price           
          equals the initial face amount.  The adjusted issue price listed            
          above is the adjusted issue price per $100 of unpaid principal              
          balance.                                                                    
               2 The Jan. 1, 1985, market price equals the middle price--             
          this is the average of the bid and asked prices.  With the                  
          exception of G-15 and G-16, Professor Schaefer used the average             
          of the bid prices obtained by Arthur Andersen and petitioner from           
          the Salomon Brothers, First Boston, Merrill Lynch, and Shearson             
          Lehman investment banks as the bid price.  See appendix.  The bid           
          prices for G-15 and G-16 equaled the average of the available               
          prices.                                                                     
               We find that petitioner’s method of valuing its favorable              
          financing intangible assets provides a reasonable estimate of               
          fair market value.  The Supreme Court in Dickman v. Commissioner,           
          465 U.S. 330, 337-338 (1984), indicated that the value of the               
          right to use borrowed money is readily measurable by reference to           
          current interest rates.  See also Rev. Proc. 85-46, sec. 3.01,              
          1985-2 C.B. 507 (stating that the value of a gift below-market              
          loan is “the difference between the rate at which the money is              
          loaned and the prevailing market rate.”).  Similarly, we believe            
          that the favorable financing aspect of petitioner’s debt                    
          instruments may be valued by comparing petitioner’s effective               
          contract interest rates to the prevailing market rates for those            






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Last modified: May 25, 2011