Fed. Home Loan Mortg. Corp. v. Comm'r
United States Tax Court
P was chartered by an act of Congress in 1970 and was originally exempt from Federal income taxation. Pursuant to the Deficit Reduction Act of 1984 (DEFRA), Pub.
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P was chartered by an act of Congress in 1970 and was originally exempt from Federal income taxation. Pursuant to the Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-369, sec. 177, 98 Stat. 709, P became subject to Federal income taxation, effective Jan. 1, 1985. For its taxable years 1985 through 1990, P claims entitlement to amortize intangibles using a fair market value basis as of Jan. 1, 1985. P's claim that it is entitled to use fair market value as its adjusted basis for amortization is based on the provisions of DEFRA that specifically apply only to P. R determined that P's adjusted…
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 00 Ol
40,111,127 CO CO 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 . 3,827,654
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,…
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