Federal Home Loan Mortgage Corporation - Page 27

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          instruments as of January 1, 1985.  The market price of each of             
          petitioner’s existing debt instruments provides an accurate                 
          indication of the price at which investors would exchange the               
          debt instruments.  That price reflects the relationship between             
          the contract rate of interest on the debt and the market rate of            
          interest as of January 1, 1985.  The market approach used by                
          petitioner captures the values of the debt instruments using the            
          prices at which willing buyers and sellers actually exchanged               
          these instruments as of the valuation date.  We find that the sum           
          of the market discounts for petitioner’s debt instruments                   
          provides a reasonable estimate of the present value of the                  
          interest costs petitioner saved by paying below-market interest             
          rates on its outstanding debt instruments on January 1, 1985.               
               B.   Respondent’s Position That Favorable Financing Has No             
                    Value                                                             
               Respondent primarily argues that petitioner failed to show             
          that the favorable financing intangibles had any value because:             
          (1) Petitioner did not show it expected to receive a stream of              
          income from the favorable financing intangible assets; (2)                  
          petitioner did not prove that it could realize the value of the             
          favorable financing; (3) the favorable financing is a contra-               
          liability, not an asset; and (4) petitioner could realize the               
          value of favorable financing only by buying back its debt                   
          instruments in the market, which would be impractical because it            
          would have to pay tax on the discharge of indebtedness.                     





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