Eastern Service Corp. v. Commissioner
United States Tax Court
P, a mortgage banker, sold mortgages to the Federal National Mortgage Association (FNMA) which it then serviced. Sec. 303(c) of the FNMA Charter Act requires a "seller-servicer" of mortgages, as a part of the proceeds received on the sale of its mortgage to FNMA, to purchase FNMA stock and to retain the stock for an average period of 15 years.
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P, a mortgage banker, sold mortgages to the Federal National Mortgage Association (FNMA) which it then serviced. Sec. 303(c) of the FNMA Charter Act requires a "seller-servicer" of mortgages, as a part of the proceeds received on the sale of its mortgage to FNMA, to purchase FNMA stock and to retain the stock for an average period of 15 years. Sec. 162(d), I.R.C. 1954, provides a deduction for stock issued pursuant to sec. 303(c) to the extent the "fair market value" of the stock on the issue date is less than the amount paid for the stock. Held, in determining "fair market value" pursuant to…
1Opinion of the Court
Eastern Service Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Eastern Service Corp. v. Commissioner
Docket No. 497-74
United States Tax Court
73 T.C. 833; 1980 U.S. Tax Ct. LEXIS 188;
February 19, 1980, Filed
Decision will be entered under Rule 155.
P, a mortgage banker, sold mortgages to the Federal National Mortgage Association (FNMA) which it then serviced. Sec. 303(c) of the FNMA Charter Act requires a "seller-servicer" of mortgages, as a part of the proceeds received on the sale of its mortgage to FNMA, to purchase FNMA stock and to retain the stock for an average…
2Cases cited21 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
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