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SAN ANTONIO SAVINGS ASSOCIATION v. COMMISSIONER

Docket No. 47016-86.

55 T.C.M. 813 (1988)

T.C. Memo. 1988-204

San Antonio Savings Association and Subsidiaries v. Commissioner.

United States Tax Court.

Filed May 5, 1988.

Attorney(s) appearing for the Case

Richard L. Bacon, 1330 Connecticut Ave., Washington, D.C., Peter J. Valeta, and William F. Cooney, for the petitioner. Kendall C. Jones, Lawrence M. Hill, Nancy Romano, and Fera M. Wagner, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Petitioner has moved for summary judgment determining that it realized and may recognize a loss from the concurrent sale of 90 percent participation interests in some of its residential first mortgage loans and purchase of 90 percent participation interests in different mortgage loans (the transaction). Three theories for disallowing the loss claimed have...

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