United States Tax Court November 21, 2005, No. 3941-99; 15626-99 (Fed. Home Loan Mortg. Corp. v. Comm'r)

lead-opinion

OPINION

Ruwe, Judge:

Respondent determined deficiencies in petitioner’s Federal income taxes in docket No. 3941-99 as follows:

Year Deficiency

M CD OO OX $36,623,695

M CD CO 05 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 taxes in docket No.