- 24 -
Co., 513 U.S. 251, 258, n.2 (1995) (determining that Comptroller
of the Currency may determine what is an “incidental powe[r] * *
* necessary to carry on the business of banking” for purposes of
12 U.S.C. sec. 24: “We expressly hold the ‘business of banking’
is not limited to the enumerated powers in � 24 Seventh and that
the Comptroller therefore has discretion to authorize activities
beyond those specifically enumerated.”)
C. Court’s Function in Interpreting the Internal Revenue
Code
This Court's function in interpreting the Internal Revenue
Code is to construe the statutory language to effectuate the
intent of Congress. See United States v. Am. Trucking
Associations, 310 U.S. 534, 542 (1940); Merkel v. Commissioner,
109 T.C. 463, 468 (1997); Fehlhaber v. Commissioner, 94 T.C.
863, 865, affd. 954 F.2d 653 (11th Cir. 1992); U.S. Padding Corp.
v. Commissioner, 88 T.C. 177, 184 (1987), affd. 865 F.2d 750 (6th
Cir. 1989). Both a textual analysis of the statute and a
consideration of Congress’ purpose in enacting Subpart F are
warranted and appropriate to determine whether deposits with
WFNNB, whose activities were predominantly limited to credit card
transactions, and which is a wholly owned subsidiary of
petitioner, are section 956 deposits. See Public Citizen v.
United States Dept. of Justice, 491 U.S. 440 (1989). We begin by
considering Congress' purpose in enacting subpart F.
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