Barnett Banks, Inc. & Subsidiaries - Page 25




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          “banks” and those chartered as “savings banks” or “savings and              
          loan associations”.  This treatment is consistent with the                  
          Federal revenue policy that recognizes that thrift institutions             
          have historically been the primary source of residential home               
          mortgages.                                                                  
               Alternatively, petitioner argues that Southwest and Pinellas           
          qualify as “mutual savings banks” as defined in section 591(b).             
          Section 591(b) expands the definition of a “mutual savings bank”            
          for purposes of section 591.  Section 591 provides:                         
               SEC. 591.  DEDUCTION FOR DIVIDENDS PAID ON DEPOSITS.                   
                    (a) In General.-–In the case of mutual savings                    
               banks, cooperative banks, domestic building and loan                   
               associations, and other savings institutions chartered                 
               and supervised as savings and loan or similar                          
               associations under Federal or State law, there shall be                
               allowed as deductions in computing taxable income                      
               amounts paid to, or credited to the accounts of,                       
               depositors or holders of accounts as dividends or                      
               interest on their deposits or withdrawable accounts, if                
               such amounts paid or credited are withdrawable on                      
               demand subject only to customary notice of intention to                
               withdraw.                                                              
                    (b) Mutual Savings Bank to Include Certain Banks                  
               With Capital Stock.-–For purposes of this part, the                    
               term “mutual savings bank” includes any bank–-                         
                         (1) which has capital stock represented by                   
                    shares, and                                                       
                         (2) which is subject to, and operates under,                 
                    Federal or State laws relating to mutual savings                  
                    bank.                                                             










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Last modified: May 25, 2011