Fed. Home Loan Mortg. Corp. v. Comm'r
United States Tax Court
P received commitment fees for entering into prior approval purchase contracts with mortgage originators. The contracts obligated P to purchase mortgages from originators during a specified period of time pursuant to a pricing formula but did not require the originators to sell mortgages to P. The commitment fees equaled 2.0 percent of the principal amount of the mortgages.
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P received commitment fees for entering into prior approval purchase contracts with mortgage originators. The contracts obligated P to purchase mortgages from originators during a specified period of time pursuant to a pricing formula but did not require the originators to sell mortgages to P. The commitment fees equaled 2.0 percent of the principal amount of the mortgages. The commitment fees consisted of a 0.5-percent nonrefundable portion and a 1.5-percent refundable portion. In the taxable years 1985 through 1990, P treated the 0.5-percent nonrefundable portion of the commitment fees as…
1Opinion of the Court
FEDERAL HOME LOAN MORTGAGE CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Fed. Home Loan Mortg. Corp. v. Comm'r
No. 3941-99; 15626-99
United States Tax Court
125 T.C. 248; 2005 U.S. Tax Ct. LEXIS 33; 125 T.C. No. 12;
November 21, 2005, Filed
Fed. Home Loan Mortg. Corp. v. Commissioner, 121 T.C. 279, 2003 U.S. Tax Ct. LEXIS 44 (2003)
P received commitment fees for entering into prior approval
purchase contracts with mortgage originators. The contracts
obligated P to purchase mortgages from originators during a
specified period of time pursuant to a pricing formula but did
not…
2Cases cited23 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Commissioner v. TuftsSupreme Court of the United States · 1983
- Estate of Franklin v. CommissionerUnited States Tax Court · 1975
- Ernest J. Saviano and Margaret Saviano v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1985
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