Centennial Savings Bank Fsb, Cross-Appellee v. United States of America, Cross-Appellant

JERRE S. WILLIAMS, Circuit Judge:

Centennial Savings Bank appeals the district court’s decision that the bank’s exchange of 90% interests in depreciated mortgages with the Federal National Mortgage Association for a separate set of 90% interests in depreciated mortgages did not result in a loss for tax purposes. Centennial also challenges the district court’s holding that the statute of limitations did not bar the IRS from assessing taxes owed. On a wholly separate issue the government cross appeals. It claims that the district court incorrectly ruled that income the bank had earned from…