Court of Appeals for the D.C. Circuit February 20, 1990, 88-1827, 88-1853 (Federal National Mortgage Association, Appellant/cross-Appellee v. Commissioner of Internal Revenue, Appellee/cross-Appellant)

Opinion for the Court filed by Circuit Judge MIKVA.

MIKVA, Circuit Judge:

Federal National Mortgage Association (“FNMA”) was severely impacted by the dramatic rise in interest rates in the late 1970s. As a result, FNMA entered into two types of mortgage transactions in the early 1980s through which it sought to improve its economic standing.