Federal Nat'l Mortgage Ass'n v. Commissioner
United States Tax Court
P entered into certain transactions in 1984 and 1985 to hedge interest rate risk related to the issuance of some of its debentures and acquisition of certain mortgages. P sustained net losses from these transactions in 1984 and 1985, which it deducted as ordinary losses.
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P entered into certain transactions in 1984 and 1985 to hedge interest rate risk related to the issuance of some of its debentures and acquisition of certain mortgages. P sustained net losses from these transactions in 1984 and 1985, which it deducted as ordinary losses. In accounting for the gain or loss associated with the hedges involving the short sale of Treasury securities, P included interest earned on the proceeds from the sale of those securities, and it deducted interest paid which was associated therewith, treating the income, expenses, and gain or loss with respect to each…
1Opinion of the Court
KÓRNER, Judge:
On April 7, 1986, respondent issued a statutory notice of deficiency to petitioner with respect to the taxable years 1971, 1973, 1974, 1975, 1977, and 1979 in which respondent determined, inter alia, deficiencies in petitioner’s corporate income tax in the amounts of $81,735,007 and $50,237,039 for taxable years 1974 and 1975, respectively.
Federal National Mortgage Association (hereinafter FNMA or petitioner) filed two petitions with this Court on June 20, 1986: (1) Docket No. 21556-86 seeking a redetermination of deficiencies determined for 1971, 1973, 1977, and 1979 relating…
2Cases cited43 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Arkansas Best Corp. v. CommissionerSupreme Court of the United States · 1988
- Smith v. CommissionerUnited States Tax Court · 1982
- Estate of Craig M. Smith, Deceased, Ruth E. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
38 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Davis v. Comm'rUnited States Tax Court · 2002
- Federal National Mortgage Association v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Gladden v. Comm'rUnited States Tax Court · 1999
- Capital One Fin. Corp. v. Comm'rUnited States Tax Court · 2009
- G.M. Trading Corp. v. CommissionerUnited States Tax Court · 1994
24 more not listed; retrieve them via the Exa API.