- 17 - 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 ofPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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