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FIRST FEDERAL SAV. & LOAN ASS'N OF TEMPLE v. U.S.

Civ. A. No. W-86-CA-117.

694 F.Supp. 230 (1988)

FIRST FEDERAL SAVINGS & LOAN ASSOCIATION OF TEMPLE, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Texas, Waco Division.

July 26, 1988.

Attorney(s) appearing for the Case

Vester T. Hughes, Jr., Cynthia M. Ohlenforst, Dallas, Tex., H. Robert Powell, Austin, Tex., for plaintiff.

Walter B. Thurmond & Grover Hartt, III, Dept. of Justice, Tax Div., Dallas, Tex., for defendant.

MEMORANDUM OPINION AND ORDER

WALTER S. SMITH, Jr., District Judge.

This cause came on for trial April 25, 1988, before the Court without a jury. Having considered the pleadings, evidence, and arguments of counsel, the Court enters the following findings of fact and conclusions of law.

I. Introduction

This case presents the relatively novel issue of the tax treatment to be given to "reciprocal mortgage sales" conducted pursuant

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