Base Offering Circular – Multifamily 52 “stripped bonds” or “stripped coupons” with respect to the remainder.  An investor should consult its tax advisor regarding this matter. A Holder of an MX Class should calculate original issue discount with respect to each Strip and include it in ordinary income as it accrues, which may be prior to the receipt of cash attributable to such income, in accordance with a constant interest method that takes into account the compounding of interest.  See “Tax Treatment of Regular Securities—Original Issue Discount” above.  The Holder should determine its yield to maturity based on its purchase price allocated to the Strip and on a schedule of payments projected using a prepayment assumption, and then make periodic adjustments to take into account actual prepayment experience.  With respect to a particular Holder, it is not clear whether the prepayment assumption used to calculate original issue discount would be determined at the time of purchase of the Strip or would be the original prepayment assumption with respect to the related Regular Class. If OID accruing with respect to a Strip, computed as described above, is negative for any period, the MX Holder will be entitled to offset such amount only against future positive OID accruing from such Strip, and the Tax Administrator intends to report income in all cases in this manner.  Although not entirely free from doubt, such a Holder may be entitled to deduct a loss to the extent that its remaining basis would exceed the maximum amount of future payments to which the Holder is entitled with respect to such Strip, assuming no further prepayments of the Mortgages (or, perhaps, assuming prepayments at a rate equal to the prepayment assumption with respect to the related Regular Class).  Although the issue is not free from doubt, all or a portion of such loss may be treated as a capital loss if the Strip is a capital asset in the hands of the Holder.  An investor should consult its tax advisor regarding this matter. An MX Holder will realize gain or loss on the sale of a Strip in an amount equal to the difference between the amount realized and its adjusted basis in such Strip.  The seller’s adjusted basis generally is equal to the seller’s allocated cost of the Strip, increased by income previously included, and reduced (but not below zero) by distributions previously received.  Except as described below, any gain or loss on such sale will be capital gain or loss if the MX Holder has held its interest as a capital asset and will be long-term if the interest has been held for the long- term capital gain holding period (more than one year).  Such gain or loss will be ordinary income or loss (i) for a bank or thrift institution or (ii) to the extent income recognized by the Holder is less than the income that would have been recognized if the yield on such interest were 110% of the applicable federal rate under section 1274(d) of the Code. If an investor exchanges a Regular Class for several MX Classes and then sells one of such MX Classes, the sale will subject the investor to the coupon stripping rules of section 1286 of the Code.  The investor must allocate its basis in the exchanged Regular Class between the part of the Regular Class underlying the MX Class sold and the part of the Regular Class underlying the MX Classes retained in proportion to their relative fair market values as of the date of such sale.  The investor is treated as purchasing the interest retained for the amount of basis allocated to such interest.  The investor must calculate original issue discount with respect to the retained interest as described above.