Legal Opinion
Federal National Mortgage Association, Appellant/cross-Appellee v. Commissioner of Internal Revenue, Appellee/cross-Appellant
Court of Appeals for the D.C. Circuit
Decided February 20, 1990No. 88-1827, 88-1853PublishedCited by 14 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge MIKVA.
MIKVA, Circuit Judge:
Federal National Mortgage Association (“FNMA”) was severely impacted by the dramatic rise in interest rates in the late 1970s. As a result, FNMA entered into two types of mortgage transactions in the early 1980s through which it sought to improve its economic standing. The Resale/Refinance program was designed to replace uneconomical low-interest mortgages in FNMA’s portfolio with higher-interest mortgages. The Concurrent Mortgage Sales program (“CMS”) was structured to allow FNMA to recognize losses in its mortgage…
2Cases cited25 opinions
- Foman v. DavisSupreme Court of the United States · 1962
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
20 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Cottage Savings Assn. v. CommissionerSupreme Court of the United States · 1991
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
- Norwest Corp. v. Comm'rUnited States Tax Court · 1998
- The Hoh Company, and George Hyman Construction Company v. The Travelers Indemnity CompanyCourt of Appeals for the D.C. Circuit · 1990
- TAIYO HAWAII CO. v. COMMISSIONERUnited States Tax Court · 1997
9 more not listed; retrieve them via the Exa API.