Director of Revenue of Mo. v. CoBank ACB, 531 U.S. 316, 10 (2001)

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Cite as: 531 U. S. 316 (2001)

Opinion of the Court

Farm Credit Banks and the capital, reserves, and surplus thereof, and the income derived therefrom, shall be exempt from Federal, State, municipal, and local taxation . . ."); § 2098 ("Each Federal land bank association and the capital, reserves, and surplus thereof, and the income derived there-from, shall be exempt from Federal, State, municipal, and local taxation . . .").

By contrast, since their creation in 1933, banks for cooperatives have been granted only limited exemptions from taxation. Had Congress intended to confer upon banks for cooperatives the more comprehensive exemption from taxation that it had provided to farm credit banks and federal land bank associations, it would have done so expressly as it had done elsewhere in the Farm Credit Act. Thus, in light of the structure of the Farm Credit Act—and the explicit grant of immunity to other institutions within the Farm Credit System—Congress' silence with respect to banks for cooperatives indicates that banks for cooperatives are subject to state taxation.

* * *

The judgment of the Missouri Supreme Court is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.

It is so ordered.

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