Dollar Rolled Mortgage Backed Securities Were Capital Assets Despite Closing Agreement on Later Years (But Never Mind, Equitable Relief Reverses the Logic)
Author: John Ensminger.
Source: Volume 20, Number 04, March/April 2007 , pp.55-61(7)
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Abstract:
In TAM 200651033, the IRS considered whether “dollar rolled” mortgage backed securities (MBSs) were acquired in the ordinary course of trade or business for services rendered within the meaning of Section 1221(a)(4). The Service’s conclusion was that the instruments were not so acquired. This TAM, issued in late August, must be considered in light of proposed regulations issued earlier the same month regarding Section 1221(a)(4), which would interpret Section 1221(a)(4) as excluding notes and accounts receivable originated by a lender in a lending transaction or purchased in the secondary market.Keywords:
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