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UNITED STATES v. CENTENNIAL SAVINGS BANK FSB

No. 89-1926.

499 U.S. 573 (1991)

UNITED STATES v. CENTENNIAL SAVINGS BANK FSB (RESOLUTION TRUST CORPORATION, RECEIVER)

Supreme Court of the United States.

Decided April 17, 1991.

Attorney(s) appearing for the Case

Acting Solicitor General Roberts argued the cause for the United States. With him on the briefs were Assistant Attorney General Peterson, Deputy Solicitor General Wallace, Clifford M. Sloan, Richard Farber, and Bruce R. Ellisen.

Michael F. Duhl argued the cause for respondent. With him on the brief were Mark L. Perlis, Frederic W. Hickman, Alfred J. T. Byrne, Colleen B. Bombardier, and Daniel R. Richards.*

JUSTICE MARSHALL delivered the opinion of the Court.*

In this case, we consider two questions relating to the federal income tax liability of respondent Centennial Savings Bank FSB (Centennial). The first is whether Centennial realized deductible losses when it exchanged its interests in one group of residential mortgage loans for another lender's interests in a different group of residential...

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