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regulation includes in the definition of a domestic building and
loan association “any other savings institution chartered and
supervised as a savings and loan or similar association under
Federal or State law” that meets the supervisory test, business
operations test, and assets test. Sec. 301.7701-13A(a), Proced.
& Admin. Regs. (Emphasis added.) Petitioner seizes upon the
phrase “similar association” in an attempt to fit within the
definition of a domestic building and loan association.
Petitioner’s interpretation of the regulation would have the
effect of substituting “any financial institution” for the
introductory language in the regulation. The regulation may have
been intended to give some flexibility to institutions chartered
in States that do not apply the same labels for “building and
loan association”; however, to interpret the phrase “similar
association” to include any financial institution that meets the
supervisory test, business operations test, and assets test of
the regulation would require us to ignore the introductory
language. We decline to do so in light of the clear intent of
Congress to distinguish among financial institutions by
incorporating the term “domestic building and loan association”
in sections 593(a)(1)(A) and 7701(a)(19).
Respondent also points to the relationship among sections
581, 585, and 593 as confirming the congressional intent to
devise a comprehensive statutory scheme for the treatment of
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