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COTTAGE SAVINGS ASSN. v. COMMISSIONER

No. 89-1965.

499 U.S. 554 (1991)

111 S.Ct. 1503

113 L.Ed.2d 589

COTTAGE SAVINGS ASSOCIATION v. COMMISSIONER OF INTERNAL REVENUE

Supreme Court of United States.

Decided April 17, 1991.

Attorney(s) appearing for the Case

Dennis L. Manes argued the cause for petitioner. With him on the briefs was Scott M. Slovin.

Acting Solicitor General Roberts argued the cause for respondent. With him on the brief were Assistant Attorney General Peterson, Deputy Solicitor General Wallace, Clifford M. Sloan, Richard Farber, and Bruce R. Ellisen.

JUSTICE MARSHALL delivered the opinion of the Court.

The issue in this case is whether a financial institution realizes tax-deductible losses when it exchanges its interests in one group of residential mortgage loans for another lender's interests in a different group of residential mortgage loans. We hold that such a transaction does give rise to realized losses.

I

Petitioner Cottage Savings Association (Cottage Savings) is a savings and loan association...

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