Legal Opinion

Fed. Home Loan Mortg. Corp. v. Comm'r

United States Tax Court

Decided September 4, 2003No. 3941-99; No. 15626-99PublishedCited by 19 opinions

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,…

2Cases cited14 opinions

  1. United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
  2. Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
  3. Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
  4. FPL Group, Inc. v. CommissionerUnited States Tax Court · 2001
  5. Rauenhorst v. Comm'rUnited States Tax Court · 2002

9 more not listed; retrieve them via the Exa API.

3Cited by19 opinions

  1. Fed. Home Loan Mortg. Corp. v. Comm'rUnited States Tax Court · 2003
  2. Capital Blue Cross & Subsidiaries v. Comm'rUnited States Tax Court · 2004
  3. Garber Indus. Holding Co. v. Comm'rUnited States Tax Court · 2005
  4. Fed. Home Loan Mortg. Corp. v. Comm'rUnited States Tax Court · 2003
  5. Fed. Home Loan Mortg. Corp. v. Comm'rUnited States Tax Court · 2005

14 more not listed; retrieve them via the Exa API.

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