Taxable Mortgage Pool

Taxable Mortgage Pool means:
any entity (other than a real estate mortgage investment conduit) if:

1. substantially all of the assets of such entity consists of debt obligations, and more than 50% of these debt obligations consists of real estate mortgages, 2. such entity is the obligor under debt obligations with two or more maturities, and.

3. payments on the debt obligations in (2) bear a relationship to payments on the debt obligations in (1).

A TMP is taxable as a separate corporation and may not be included in a consolidated tax return. Former IRC (check if this IRC provision is current here) §7701(i).