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 had entered into certain financing arrangements before Jan. 1, 1985, the proceeds of which were used in P's mortgage business.
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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 had entered into certain financing arrangements before Jan. 1, 1985, the proceeds of which were used in P's mortgage business. As of Jan. 1, 1985, the contract rates of interest on these financing arrangements were less than the market rates of interest as of that date, because of an increase in interest rates since the date on which P entered into the respective arrangements. P claims that the…
1Opinion of the Court
OPINION
Ruwe, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes in docket No. 3941-99 for 1985 and 1986 as follows:
Year Deficiency
$36,623,695 co CO Ol
40,111,127 CO 00 O
Petitioner claims overpayments of $9,604,085 for 1985 and $12,418,469 for 1986.
Respondent determined deficiencies in petitioner’s Federal income taxes in docket No. 15626-99 for 1987, 1988, 1989, and 1990 as follows:
Year Deficiency
1987 . $26,200,358
1988 . 13,827,654
1989 . 6,225,404
1990 . 23,466,338
Petitioner claims overpayments of $57,775,538 for 1987, $28,434,990 for 1988, $32,577,346 for 1989, and…
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