Common use of PRELIMINARY STATEMENT Clause in Contracts

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each a ".

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, Fund be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, Fund be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, be treated for For federal income tax purposes as comprising purposes, the Trust Fund will consist of two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Yield Maintenance Agreements, other than the Supplemental Loan Account Yield Maintenance Reserve Funds and the Capitalized Interest Account, Carryover Reserve Fund) be treated for federal income tax purposes as comprising two four real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinThe Trust Fund (excluding the Corridor Contracts, the Trustee will elect that Credit Comeback Excess Account, the Trust Fund, other than the Supplemental Loan Account Carryover Reserve Fund and the Capitalized Interest assets held in the Pre-Funding Account, be treated ) for federal income tax purposes as comprising two real estate mortgage investment conduits will consist of four REMICs (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, Fund be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each each, a "REMIC" or, in the alternative, "REMIC 1," "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, The Trust Fund is being conveyed to the Trustee will elect that to create a trust for the benefit of the Certificateholders. The Trust Fund, other than any Class P Prepayment Charges, the Supplemental Loan Excess Reserve Fund Account, the Yield Maintenance Agreements and the Yield Maintenance Reserve Account and the Capitalized Interest Accountany proceeds thereof, will be treated for federal income tax purposes as comprising two real estate mortgage investment conduits REMICs (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than Fund (except for the Supplemental Loan Account and the Capitalized Interest Account, ) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinThe Trust Fund (excluding the Credit Comeback Excess Account, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account Carryover Reserve Fund and the Capitalized Interest assets held in the Pre-Funding Account, be treated ) for federal income tax purposes as comprising two real estate mortgage investment conduits will consist of four REMICs (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, Fund be treated for federal income tax purposes as comprising two a real estate mortgage investment conduits conduit (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund (excluding the Carryover Reserve Fund, other than the Supplemental Loan assets held in the Pre-Funding Account and the Capitalized Interest Account, Trust Fund's rights with respect to payments received under the Corridor Contract) be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinThe Trust Fund (excluding the Credit Comeback Excess Account, the Trustee will elect that Carryover Reserve Fund, the assets held in the Pre-Funding Account and the Trust Fund, other than 's rights with respect to payments received under the Supplemental Loan Account and the Capitalized Interest Account, be treated Corridor Contracts) for federal income tax purposes as comprising two real estate mortgage investment conduits will consist of four REMICs (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Yield Maintenance Agreements, other than the Supplemental Loan Account Yield Maintenance Reserve Funds and the Capitalized Interest Account, Carryover Shortfall Reserve Fund) be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Yield Maintenance Agreement, other than the Supplemental Loan Account Yield Maintenance Reserve Fund and the Capitalized Interest Account, Carryover Shortfall Reserve Fund) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, The Trust Fund is being conveyed to the Trustee will to create a trust for the benefit of the Certificateholders. The Trustee shall elect that two segregated asset pools within the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, Fund be treated for federal income tax purposes as comprising two real estate mortgage investment conduits REMICs (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than Fund (except for the Supplemental Loan Account Accounts and the Capitalized Interest Account, Accounts) be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, Fund be treated for federal income tax purposes as comprising two four real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest AccountCarryover Shortfall Reserve Fund, be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Yield Maintenance Agreements, other than the Supplemental Loan Account Yield Maintenance Reserve Funds and the Capitalized Interest Account, Carryover Reserve Fund) be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, be treated for For federal income tax purposes as comprising two purposes, the Trust Fund will consist of four real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Swap Contract, other than the Supplemental Loan Account and the Capitalized Interest Swap Account, the Carryover Reserve Fund and any amounts in respect of waived Prepayment Charges paid by the Servicer to the Class C Certificates pursuant to the second paragraph of Section 3.21) be treated for federal income tax purposes as comprising two four real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Swap Trust, other than the Supplemental Loan Swap Contract, the Swap Account, the Cap Trust, the Cap Contract, the Cap Account and the Capitalized Interest Account, Carryover Reserve Fund) be treated for federal income tax purposes as comprising two four real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee Trust Administrator will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, Fund be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest AccountCarryover Shortfall Reserve Fund, be treated for federal income tax purposes as comprising two four real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Yield Maintenance Agreements, other than the Supplemental Loan Account Yield Maintenance Reserve Fund and the Capitalized Interest Account, Carryover Shortfall Reserve Fund) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each each, a "“

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than Fund (except for the Supplemental Loan Account Corridor Contract and the Capitalized Interest Account, Carryover Reserve Fund) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust Fund, Fund (other than the Supplemental Loan Account and the Capitalized Interest Account, Carryover Shortfall Reserve Fund) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust Fund, other than Fund (exclusive of the Supplemental Loan Account Carryover Reserve Fund and any amounts in respect of waived Prepayment Charges paid by the Capitalized Interest Account, Servicer to the Class P Certificates pursuant to the second paragraph of Section 3.20 hereof ) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinThe Trust Fund (excluding the Corridor Contracts, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Credit Comeback Excess Account and the Capitalized Interest Account, be treated Carryover Reserve Fund) for federal income tax purposes as comprising two real estate mortgage investment conduits will consist of three REMICs (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, for federal income tax purposes, the Trustee will elect that to treat the Trust Fund, Fund (other than entitlement to the Supplemental Loan Account and the Capitalized Interest Account, be treated for federal income tax purposes Underlying Net Rate Carryover Payments) as comprising two a real estate mortgage investment conduits conduit (each a "“

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, Fund be treated for federal income tax purposes as comprising of two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund (excluding the Carryover Reserve Fund, other than the Supplemental Loan assets held in the Pre-Funding Account and the Capitalized Interest Account, Trust Fund's rights with respect to payments received under the Corridor Contract) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, The Trust Fund is being conveyed to the Trustee will elect that to create a trust for the benefit of the Certificateholders. The Trust Fund, other than any Class P Prepayment Charges, the Supplemental Loan Excess Reserve Fund Account, the Yield Maintenance Agreement and the Yield Maintenance Reserve Account and the Capitalized Interest Accountany proceeds thereof, will be treated for federal income tax purposes as comprising two real estate mortgage investment conduits REMICs (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, be treated for For federal income tax purposes as comprising two purposes, the Trust Fund (excluding the Corridor Contract and Carryover Shortfall Reserve Fund) will consist of four real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinFor federal income tax purposes, the Trustee will elect that the Trust Fund, Fund (other than the Supplemental Loan Account Carryover Reserve Fund, the Corridor Contracts, the Corridor Floor Contract, the Corridor Contract Reserve Fund and the Capitalized Supplemental Interest AccountTrust), be treated for federal income tax purposes as comprising two will consist of five real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Yield Maintenance Agreements, other than the Supplemental Loan Account Yield Maintenance Reserve Funds and the Capitalized Interest Account, Carryover Shortfall Reserve Fund) be treated for federal income tax purposes as comprising two four real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Yield Maintenance Agreement, other than the Supplemental Loan Account Yield Maintenance Reserve Fund and the Capitalized Interest Account, Carryover Shortfall Reserve Fund) be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will shall elect that the Trust Fund, other than Fund (except for the Supplemental Loan Interest Rate Hedge Account and the Capitalized Interest Account, Rate Hedge Agreements) be treated for federal income tax purposes as comprising two five real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, Fund (other than the Supplemental Loan Account Corridor Contracts and the Capitalized Interest Account, assets in the Corridor Contract Reserve Fund and the Carryover Shortfall Reserve Fund) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Yield Maintenance Agreement, other than the Supplemental Loan Account Yield Maintenance Reserve Fund and the Capitalized Interest Account, Carryover Reserve Fund) be treated for federal income tax purposes as comprising two five real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, for federal income tax purposes, (1) the Yield Supplement Trust will be a Grantor Trust owned by the Underlying Certificate Seller and (2) the Trustee will elect that to treat the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, be treated for federal income tax purposes Fund as comprising two a real estate mortgage investment conduits conduit (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Cap Contract, other than the Supplemental Loan Account Carryover Reserve Fund and any amounts in respect of waived Prepayment Charges paid by the Capitalized Interest Account, Servicer to the Class P Certificates pursuant to the second paragraph of Section 3.20) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust Fund (exclusive of the Yield Maintenance Agreements, Yield Maintenance Reserve Funds and Carryover Shortfall Reserve Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, ) be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, for federal income tax purposes, the Trustee will elect that to treat the Trust Fund, Fund (other than the Supplemental Loan Account and the Capitalized Interest Account, be treated for federal income tax purposes Yield Supplement Reserve Fund) as comprising two a real estate mortgage investment conduits conduit (each a "“

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinFor federal income tax purposes, the Trustee will elect that the Trust Fund, Fund (other than the Supplemental Loan Account and Account, the Capitalized Interest Account, be treated for federal income tax purposes as comprising two the Cap Contracts and the Reserve Funds) will consist of three real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than Fund (except for the Supplemental Loan Account and the Capitalized Interest Account, ) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust FundFund (except for the Cap Contract, other than the Supplemental Loan Account Carryover Reserve Fund and the Capitalized Interest Pre-Funding Account, ) be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund (except for the Class I-A-3 Reserve Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, ) be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust Fund (exclusive of the Carryover Reserve Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, ) be treated for federal income tax purposes as comprising two four real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, Fund be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided herein, the Trustee will elect that the Trust Fund (excluding the Carryover Reserve Fund, other than the Supplemental Loan assets held in the Pre-Funding Account and the Capitalized Interest Account, Account and the Trust Fund's rights with respect to payments received under the Corridor Contract) be treated for federal income tax purposes as comprising two real estate mortgage investment conduits (each a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust FundFund (exclusive of the Swap Trust, other than the Supplemental Loan Account Swap Contracts, the Carryover Reserve Fund and any amounts in respect of waived Prepayment Charges paid by the Capitalized Interest Account, Servicer to the Class P Certificates pursuant to the second paragraph of Section 3.20) be treated for federal income tax purposes as comprising two four real estate mortgage investment conduits (each each, a "

PRELIMINARY STATEMENT. The Depositor is the owner of the Trust Fund that is hereby conveyed to the Trustee in return for the Certificates. As provided hereinin this Agreement, the Trustee will shall elect that the Trust Fund (excluding the Reserve Fund, other than the Supplemental Loan Account and the Capitalized Interest Account, ) be treated for federal income tax purposes as comprising two three real estate mortgage investment conduits (each each, a "