Legal Opinion
Federal Home Loan Mortgage Corporation v. Commissioner
United States Tax Court
Decided November 21, 2005No. 3941-99, 15626-99Unknown
1Opinion of the Court
125 T.C. No. 12
UNITED STATES TAX COURT FEDERAL HOME LOAN MORTGAGE CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 3941-99, 15626-99. Filed November 21, 2005. 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…
2Cases cited24 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
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