Legal Opinion

Federal Nat'l Mortg. Asso. v. Commissioner

United States Tax Court

Decided March 14, 1988No. Docket No. 21556-86Published

P exchanged interests in pools of mortgage loans it owned for interests in pools of mortgage loans owned by unrelated third parties. Held, P realized recognizable losses on the exchanges. Secs. 165, 1001, I.R.C. 1954. P purchased mortgage loans that had been made by unrelated lenders. The proceeds of the mortgage loans were used, in part, to repay other mortgage loans that P owned.

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P exchanged interests in pools of mortgage loans it owned for interests in pools of mortgage loans owned by unrelated third parties. Held, P realized recognizable losses on the exchanges. Secs. 165, 1001, I.R.C. 1954. P purchased mortgage loans that had been made by unrelated lenders. The proceeds of the mortgage loans were used, in part, to repay other mortgage loans that P owned. Held, P did not exchange the mortgage loans that had been repaid for the mortgage loans it purchased. Held, further, P realized taxable gain when its bases in the mortgage loans that were repaid were less than the…

1Opinion of the Court

Federal National Mortgage Association, Petitioner v. Commissioner of Internal Revenue, Respondent

Federal Nat'l Mortg. Asso. v. Commissioner

Docket No. 21556-86

United States Tax Court

90 T.C. 405; 1988 U.S. Tax Ct. LEXIS 28; 90 T.C. No. 29;

March 14, 1988. March 14, 1988, Filed

Decision will be entered under Rule 155.

P exchanged interests in pools of mortgage loans it owned for interests in pools of mortgage loans owned by unrelated third parties. Held, P realized recognizable losses on the exchanges. Secs. 165, 1001, I.R.C. 1954.

P purchased mortgage loans that had been made by unrelated lenders.…

2Cases cited21 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
  3. n.sidney Nyhus v. Travel Management CorporationCourt of Appeals for the D.C. Circuit · 1972
  4. Bolger v. CommissionerUnited States Tax Court · 1973
  5. Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Ninth Circuit · 1966

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