Fed. Home Loan Mortg. Corp. v. Comm'r
United States Tax Court
P received commitment fees for entering into prior approval purchase contracts with mortgage originators. The contracts obligated P to purchase mortgages from originators during a specified period of time pursuant to a pricing formula but did not require the originators to sell mortgages to P. The commitment fees equaled 2.0 percent of the principal amount of the mortgages.
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P received commitment fees for entering into prior approval purchase contracts with mortgage originators. The contracts obligated P to purchase mortgages from originators during a specified period of time pursuant to a pricing formula but did not require the originators to sell mortgages to P. The commitment fees equaled 2.0 percent of the principal amount of the mortgages. The commitment fees consisted of a 0.5-percent nonrefundable portion and a 1.5-percent refundable portion. In the taxable years 1985 through 1990, P treated the 0.5-percent nonrefundable portion of the commitment fees as…
1Opinion of the Court
OPINION
Ruwe, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes in docket No. 3941-99 as follows:
Year Deficiency
M CD OO OX $36,623,695
M CD CO 05 40,111,127
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 as follows:
Year Deficiency
1987 . $26,200,358
1988 . 13,827,654
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, and $19,504,333 for 1990.
In this Opinion, we…
2Cases cited23 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Commissioner v. TuftsSupreme Court of the United States · 1983
- Estate of Franklin v. CommissionerUnited States Tax Court · 1975
- Ernest J. Saviano and Margaret Saviano v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1985
18 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
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- Williams v. Comm'rUnited States Tax Court · 2011
- Fed. Home Loan Mortg. Corp. v. Comm'rUnited States Tax Court · 2005
- Federal Home Loan Mortgage Corporation v. CommissionerUnited States Tax Court · 2005