Cite as: 531 U. S. 316 (2001)
Syllabus
§ 2134 that had become superfluous once the United States no longer owned, and no longer could own, stock in banks for cooperatives. Pp. 321-324.
(b) The Act's structure confirms that banks for cooperatives are subject to state taxation. With respect to each lending institution in the Farm Credit System, the Act contains a taxation provision that specifically delineates that entity's tax immunity. Banks for cooperatives have been granted only limited tax exemptions. Had Congress intended to confer upon them the more comprehensive exemption it provided for other types of institutions, it would have done so expressly. Pp. 324-325.
10 S. W. 3d 142, reversed and remanded.
Thomas, J., delivered the opinion for a unanimous Court.
James R. Layton, State Solicitor of Missouri, argued the cause for petitioner. With him on the briefs were Jeremiah W. (Jay) Nixon, Attorney General of Missouri, and Gail Vasterling and David Lieber, Assistant Attorneys General.
David C. Frederick argued the cause for the United States as amicus curiae urging reversal. With him on the brief were Solicitor General Waxman, Acting Assistant Attorney General Junghans, Deputy Solicitor General Wallace, David English Carmack, and Donald B. Tobin.
Richard A. Hanson argued the cause for respondent. With him on the brief was Theodore R. Bots.*
*Briefs of amici curiae urging reversal were filed for the State of Ohio et al. by Betty D. Montgomery, Attorney General of Ohio, Edward B. Foley, State Solicitor, and Robert C. Maier, Assistant Solicitor, and by the Attorneys General for their respective States as follows: Bruce M. Botelho of Alaska, Janet Napolitano of Arizona, Robert A. Butterworth of Florida, Thurbert E. Baker of Georgia, Earl I. Anzai of Hawaii, James E. Ryan of Illinois, Karen M. Freeman-Wilson of Indiana, Richard P. Ieyoub of Louisiana, J. Joseph Curran, Jr., of Maryland, Jennifer M. Granholm of Michigan, Mike Moore of Mississippi, Joseph P. Mazurek of Montana, Don Stenberg of Nebraska, Philip T. McLaughlin of New Hampshire, Eliot Spitzer of New York, Heidi Heitkamp of North Dakota, W. A. Drew Edmondson of Oklahoma, Hardy Myers of Oregon, Mark Barnett of South Dakota, William H. Sorrell of Vermont, and Christine O. Gregoire of Washington; for the American Bankers Association by John J. Gill III,
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