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FEDERAL HOME LOAN MORTGAGE CORPORATION v. COMMISSIONER

Docket No. 3941-99, 15626-99.

86 T.C.M. 492 (2003)

T.C. Memo. 2003-298

Federal Home Loan Mortgage Corporation v. Commissioner.

United States Tax Court.

Filed October 27, 2003.

Attorney(s) appearing for the Case

Robert A. Rudnick, Stephen J. Marzen, James F. Warren, and Neil H. Koslowe, for the petitioner.

Gary D. Kallevang, for the respondent.

MEMORANDUM OPINION

RUWE, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes in Docket No. 3941-99 for 1985 and 1986, as follows:

Year                    Deficiency

1985 ................     $36,623,695
1986 ................      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...

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