County and county treasurer brought action against Fannie Mae and Freddie Mac, seeking recovery of allegedly unpaid transfer taxes that were due on real estate transactions that defendants recorded with county register of deeds. The Federal Housing Finance Agency (FHFA) intervened as defendants’ conservator under Housing and Economic Recovery Act (HERA), and state officials intervened as state plaintiffs.
The court of appeals held that Federal statutory exemptions from “all taxation” for Fannie Mae, Freddie Mac, and FHFA, as conservator, applied to Michigan transfer taxes on real estate transactions.