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.oooo AT&T LTE T 72% 12:38 PM oyez.org for respondent DECIDED Apr 17, 1991 Facts of the case For tax purposes, Cottage Savings Association exchanged its interests in the mortgages of 252 single family homes with several other savings and loan associations, receiving in return 305 mortgages that, taken together, had the same market value. The fair market value of the mortgages it gave away, however, were worth $2.5 million less than their original value. In accordance with the accounting procedures of the federal regulatory body of savings and loan corporations, the Federal Home Loan Bank Board (FHLBB), Cottage Savings recorded the exchanged properties as "substantially identical" (because they had the same fair market value). When Cottage Savings filed its federal income tax return, however, it claimed a $2.5 million loss the difference between the original value IIT Chicago-Kent College of Law LLINOISINSTITUTE OF TECHNOLOGY