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
FEDERAL NATIONAL MORTGAGE ASSOCIATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Federal Nat'l Mortgage Ass'n v. Commissioner
Docket No. 21557-86
United States Tax Court
100 T.C. 541; 1993 U.S. Tax Ct. LEXIS 36; 100 T.C. No. 36;
June 17, 1993, Filed
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…
Also in this document: Concurrence.
2Cases cited44 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
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