morning your honor may it please the court this morning i will explain that the buyer is a fannie mae and freddie mac's real property are not exempt from the city's transfer tax neither the language in the three federal statutes a issue nor this one court precedent supports such an exemption so the city has not been preempted here each federal statute at issue examined three h the statute that's a specific entity from local taxation steps statutes exempt those three entities including various types of assets held by those affected the city of chicago does not require any of those entities to pay the transfer tax or impose a tax on their assets  and those entities right a buyer absolutely does not come in what about those entities who are they look like some sort of a government they definitely have a distinct relationship with the government it's changed over time they've been independent entities now they're under conservatorship of the f h a and they do have expressed statutory exemptions and we don't dispute is court decided in dekalb that that exemption does apply to them when when a transfer tax is opposed on them we submit it does not apply when it is imposed on the buyers of the real property because the city's transfer tax is imposed on the transferee and it's owed at the time that the transfer receives all records the deed so the exemptions in the federal statutes for fannie mae freddie mac n f h f a do not apply to transfer buys the property for a certain amount of that's correct so the situation here is not meaningfully different than what is involved in the supreme court cases involving the munity of the federal government from state and local taxation i understand that this is a statutory exemption but there  by analogy where the federal government enjoys the immunity from state and local taxation the supreme court has held there is no basis to include other entities even when they are closely involved with governmental functions and property we cite a number of those cases in our brief as  as construction resubmit that here too no one else should get the benefit of an exemption that is clearly assigned to three specific entities now a statute could be drafted so that it is not into too specific but here it was not and to illustrate how a statute can be drafted so it is not limited to one specific entity i'd like to highlight a passage from bismark lumber which is a case that both parties cited that compares two different types of exemption were at issue in that statute which was the federal farm loan act in a way that highlights the limitation of an entity specific exemption and there was an exemption there similar to the one here for the specific entity at issue there which the federal land bank but there was also a second exemption for one that covers two specific types of assets mortgages and loan bonds and the court explained that the second type of exemption was a proper addition because the entity specific exemption because the bonds may be held by private persons and of course the general exemption would not extend to them and quote in the course similarly said that the general entities pacific exemption would quote protect mortgages executed to the land banks and held by them but it would not survive a transfer and quote so this passage makes clear that the general entity specific exemptions  the plaintiffs rely heavily on the warrants federal savings and loan case and that is the only case involving an entity specific exemption in which the local tax was being demanded of anyone besides the particular entity identified as exempt in the statute  instead of the federal home loan bank it was the savings and loan institution that owed the tax but even though the savings and loan was a tax the taxpayer the taxpayer there the exemption was applied to the bank's advances specifically the tax the state tax was on promissory notes i had been issued to the bank so it was a tax on the bank's property even if under the statute someone else would pay it and there's nothing like that here the transfer tax is not the protection that yes we submit the dischord era to that because there is no support in the plain language of the three statutes at issue that exempt fannie mae and freddie mac but not their buyers and there's a reason that pla language is so important as you mentioned there are policy justifications on both sides and so it's up to congress to balance those state and local taxation is important so while congress wants to give you know fannie mae a boost and some leeway with some tax cuts it can do that while preserving a measure of local taxation on buyers and that balance makes sense since it is the buyer of chicago property that will benefit from the miscible services fannie mae's ex includes the language mortgages which the plaintiffs have emphasized and we submit the city's transfer tax is not a tax something means mortgage the term mortgage standing alone does not mean the entire mortgage investment process as plaintiffs are you they compare that term to the broader meaning of the terms loan and advances which were in the statutes at issue in pittman and lawrence but we submit that a loan or advances can be made up of component parts freddie mac's statute is a little bit different in that it is different kind because it also includes activity on the on the in the including clause not rather than just assets or property but regardless t buyers we submit that it is the buyers activity not the sellers that is the subject here so in conclusion the statutory entity specific language is not worded in a way that applies an exemption to all parties involved in a particular transaction there is a way to achieve that with plain language directed at the transaction itself either transfer specifically or transactions more generally but congress just didn't do that here congress wrote these three the city of chicago it's an important source of tax revenue in the city of chicago no it doesn't this doesn't impact what happens on the foreclosure end of it but the sale between fannie mae and