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stipulated facts accordingly, and we set forth the relevant facts
in this background section. We also set forth in this section,
as they relate to the operation of the FDIC and of the insurance
funds at issue, the pertinent provisions of title 12 of the
United States Code (1994) (title 12).
Petitioner is a Delaware corporation whose principal office
was in East Moline, Illinois, when its petition was filed. It is
a bank holding company that files consolidated Federal income tax
returns.2 It reports its income and expenses using an accrual
method and on the basis of a fiscal year ending on October 31.
It includes in its consolidated returns a wholly owned
subsidiary, Metrobank, that is a bank chartered in Illinois.
The FDIC is a congressionally established corporation that
serves primarily to protect financial institution depositors by
insuring any deposit up to $100,000 that is held by a bank or
savings association participating in the FDIC insurance program.
The Banking Insurance Fund (BIF) and the Savings Association
Insurance Fund (SAIF) are separate funds which the FDIC maintains
and administers under this program. The BIF insures the deposit
liabilities of participating banks, e.g., Metrobank. The SAIF
2 For purposes of title 12, the term “bank” generally refers
to a State-chartered bank, and the term “savings association”
generally refers to a Federal- or State-chartered savings
association (or savings and loan or thrift as it is sometimes
called). 12 U.S.C. sec. 1813(a) and (b) (1994). We use herein
the same terminology. We refer collectively to banks and savings
associations as financial institutions.
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