Barnett Banks, Inc. & Subsidiaries - Page 17




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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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