Fed. Home Loan Mortg. Corp. v. Comm'r
United States Tax Court
P was originally exempt from Federal income taxation. However, on Jan. 1, 1985, P became subject to taxation under the Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-369, sec. 177, 98 Stat. 709. P adopted the accrual method of accounting for its first taxable year commencing Jan. 1, 1985. Before that date, P acquired certain mortgages that were in default.
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P was originally exempt from Federal income taxation. However, on Jan. 1, 1985, P became subject to taxation under the Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-369, sec. 177, 98 Stat. 709. P adopted the accrual method of accounting for its first taxable year commencing Jan. 1, 1985. Before that date, P acquired certain mortgages that were in default. Interest accrued on each of those mortgages from the date of acquisition up to Jan. 1, 1985. At various points after Jan. 1, 1985, P foreclosed the mortgages on the underlying real estate. In computing its gain or loss from the…
1Opinion of the Court
Federal Home Loan Mortgage Corp. v. Commissioner
Fed. Home Loan Mortg. Corp. v. Comm'r
No. 3941-99; No. 15626-99
United States Tax Court
121 T.C. 279; 2003 U.S. Tax Ct. LEXIS 44; 121 T.C. No. 15;
October 30, 2003, Filed
Fed. Home Loan Mortg. Corp. v. Commissioner, T.C. Memo 2003-298, 2003 Tax Ct. Memo LEXIS 300 (T.C., 2003)
P was originally exempt from Federal income taxation.
However, on Jan. 1, 1985, P became subject to taxation under the
Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-369, sec. 177,
98 Stat. 709. P adopted the accrual method of accounting for its
first taxable year commencing Jan.…
2Cases cited12 opinions
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2001
- Rauenhorst v. Comm'rUnited States Tax Court · 2002
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- Collin v. CommissionerUnited States Board of Tax Appeals · 1925
- Citizens' Acceptance Corporation, a Dissolved Corporation Continued by Statute for Purposes of Suit v. United StatesCourt of Appeals for the Third Circuit · 1972
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