Barnett Banks, Inc. & Subsidiaries - Page 15




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          contends that an institution that satisfies these tests thereby             
          qualifies as a domestic savings and loan association.  Section              
          301.7701-13A(a), Proced. & Admin. Regs., adds to the list of                
          institutions that are domestic building and loan associations               
          “any other savings institution chartered and supervised as a                
          savings and loan or similar association under Federal or State              
          law which meets the * * * [three tests]”.  According to                     
          petitioner, the effect of this regulation is to allow the use of            
          the reserve method of accounting under section 593 by any                   
          “similar association” that meets the three tests.  Both parties             
          cite the evolution of the term “building and loan association” in           
          the Code and associated legislative history in support of their             
          respective positions.                                                       
               The definition of a “building and loan association” under              
          section 101(4), I.R.C. 1939, was expanded to include “a domestic            
          building and loan association, a domestic savings and loan                  
          association, and a Federal savings and loan association,                    
          substantially all the business of which is confined to making               
          loans to members” by the Revenue Act of 1951, ch. 521, sec. 313,            
          65 Stat. 490.  In that Act, Congress eliminated the exemption               
          from Federal income tax for domestic building and loan                      
          associations and instead enacted generous rules for calculating             
          deductions for additions to bad debt reserves.  Revenue Act of              
          1951, ch. 521, sec. 313(e), 65 Stat. 490-491.  The legislative              






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