Barnett Banks, Inc. & Subsidiaries - Page 16




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          history for the 1951 Act indicates:  “This amendment is of a                
          clarifying nature and is not intended to change the existing                
          meaning of a domestic building and loan association”.  S. Rept.             
          781, 82d Cong., 1st Sess. (1951), 1951-2 C.B. 563-564.                      
          Petitioner cites this report in support of its position that,               
          although the definition of a domestic building and loan                     
          association has expanded, the law has never required a specific             
          type of charter, thereby excluding those institutions whose                 
          substantial business would otherwise qualify for the benefits of            
          the bad debt reserve calculation.                                           
               Congress again altered the rules for calculating bad debt              
          reserves for building and loan associations by deleting the                 
          reference to “loans to members” and replacing it with the                   
          supervisory test, business operations test, and assets test,                
          codified in section 7701(a)(19).  Revenue Act of 1962, Pub. L.              
          87-834, sec. 6(c), 76 Stat. 977.                                            
               Respondent asserts that, throughout the evolution of the               
          definition of a domestic building and loan association, the                 
          introductory language quoted supra p. 12 has remained in the                
          statute, demonstrating congressional intent to distinguish                  
          between entities classified as domestic building and loan                   
          associations and banks.                                                     
               The introductory language of section 7701(a)(19) is also               
          found in section 301.7701-13A(a), Proced. & Admin. Regs.  That              






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