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26 U.S.C.A. § 597
I.R.C. § 597 |
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Effective:[See Text Amendments]
United States Code Annotated Currentness
Title 26. Internal Revenue Code (Refs & Annos)
Subtitle A. Income Taxes (Refs & Annos)
Chapter 1. Normal Taxes and Surtaxes (Refs & Annos)
Subchapter
H.
Banking Institutions
Part
II.
Mutual Savings Banks, Etc. (Refs
& Annos)
§
597. Treatment of transactions in which Federal financial assistance
provided
(a) General rule.--The treatment for purposes of this chapter of any transaction in which Federal financial assistance is provided with respect to a bank or domestic building and loan association shall be determined under regulations prescribed by the Secretary.
(b) Principles used in prescribing regulations.--
(1) Treatment of taxable asset acquisitions.--In the case of any acquisition of assets to which section 381(a) does not apply, the regulations prescribed under subsection (a) shall--
(A) provide that Federal financial assistance shall be properly taken into account by the institution from which the assets were acquired, and
(B) provide the proper method of allocating basis among the assets so acquired (including rights to receive Federal financial assistance).
(2) Other transactions.--In the case of any transaction not described in paragraph (1), the regulations prescribed under subsection (a) shall provide for the proper treatment of Federal financial assistance and appropriate adjustments to basis or other tax attributes in connection with such assistance.
(3) Denial of double benefit.--No regulations prescribed under this section shall permit the utilization of any deduction (or other tax benefit) if such amount was in effect reimbursed by nontaxable Federal financial assistance.
(c) Federal financial assistance.--For purposes of this section, the term “Federal financial assistance” means--
(1) any money or other property provided with respect to a domestic building and loan association by the Federal Savings and Loan Insurance Corporation or the Resolution Trust Corporation pursuant to section 406(f) of the National Housing Act or section 21A of the Federal Home Loan Bank Act (or under any other similar provision of law), and
(2) any money or other property provided with respect to a bank or domestic building and loan association by the Federal Deposit Insurance Corporation pursuant to section 11(f) or 13(c) of the Federal Deposit Insurance Act (or under any other similar provision of law),
regardless of whether any note or other instrument is issued in exchange therefor.
(d) Domestic building and loan association.--For purposes of this section, the term “domestic building and loan association” has the meaning given such term by section 7701(a)(19) without regard to subparagraph (C) thereof.
(Added Pub.L. 97-34, Title II, § 244(a), Aug. 13, 1981, 95 Stat. 255; amended Pub.L. 99-514, Title IX, § 904(b)(1), Oct. 22, 1986, 100 Stat. 2385; Pub.L. 100-647, Title IV, § 4012(b)(2)(A) to (D)(i), (c)(1), Nov. 10, 1988, 102 Stat. 3657, 3658; Pub.L. 101-73, Title XIV, § 1401(a)(3)(A), Aug. 9, 1989, 103 Stat. 548; Pub.L. 101-239, Title VII, § 7841(e)(1), Dec. 19, 1989, 103 Stat. 2429; Pub.L. 101-508, Title XI, § 11704(a)(7), Nov. 5, 1990, 104 Stat. 1388-518.)
HISTORICAL AND STATUTORY NOTES
Revision Notes and Legislative Reports
1981 Acts. Senate Report No. 97-144, House Conference Report No. 97-215, and Statements by Legislative Leaders, see 1981 U.S. Code Cong. and Adm. News, p. 105.
1989 Acts. House Report No. 101-247 and House Conference Report No. 101-386, see 1989 U.S. Code Cong. and Adm. News, p. 1906.
House Report No. 101-54 and House Conference Report No. 101-209, see 1989 U.S. Code Cong. and Adm. News, p. 86.
1990 Acts. House Report No. 101-881 and House Conference Report No. 101-964, see 1990 U.S. Code Cong. and Adm. News, p. 2017.
References in Text
Section 406(f) of the National Housing Act, referred to in subsec. (c)(1), is Act June 27, 1934, c. 847, Title IV, § 406(f), 48 Stat. 1259, which is classified to section 1729(f) of Title 12, Banks and Banking.
Section 21A of the Federal Home Loan Bank Act, referred to in subsec. (c)(1), is Act July 22, 1932, c. 522, § 21A, as added Pub.L. 101-73, Title V, § 501(a), Aug. 9, 1989, 103 Stat. 363, which is classified to section 1441a of Title 12, Banks and Banking.
Section 11(f) or 13(c) of the Federal Deposit Insurance Act, referred to in subsec. (c)(2), are Act Sept. 21, 1950, c. 967, §§ 2[11(f)], 2[13(c)], 64 Stat. 884, 888, and are classified to section 1821(f) and 1823(c), respectively, of Title 12, Banks and Banking.
Amendments
1990 Amendments. Subsec. (c). Pub.L. 101-508, § 11704(a)(7), substituted “For purposes of” for “The purposes of”.
1989 Amendments. Pub.L. 101-73, § 1401(b)(1), repealed amendment made by Pub.L. 99-514, § 904(b)(1). See 1986 Amendment note below.
Subsec. (a). Pub.L. 101-73 substituted provisions that treatment of any transaction in which Federal financial assistance is provided shall be by regulations prescribed by the Secretary for provisions excluding from gross income of a domestic building and loan association any money from the Federal Savings and Loan insurance Corporation pursuant to section 406(f) of the National Housing Act and from a bank any money received from the Federal Deposit Insurance Corporation pursuant to sections 13(c), 15(c)(1), and 15(c)(2) of the Federal Deposit Insurance Corporation.
Subsec. (b). Pub.L. 101-73 substituted provisions relating to the principles used in prescribing regulations for provisions mandating no reduction in basis of assets on account of money received from federal financial assistance.
Subsec. (b)(2). Pub.L. 101-239, § 7841(e)(1), substituted “in connection with such assistance” for “to reflect such treatment”.
Subsec. (c). Pub.L. 101-73 substituted provisions defining the term “Federal financial assistance” for provisions relating to reduction of tax attributes by 50 percent of amounts excludable under subsection (a).
Subsec. (d). Pub.L. 101-73 reenacted subsec. (d) without change.
1988 Amendments. Heading. Pub.L. 100-647, § 4012(b)(2)(D)(i), substituted “FSLIC or FDIC” for “FSLIC”.
Subsec. (a). Pub.L. 100-647, § 4012(b)(2)(A), added the sentence “Gross income of a bank does not include any amount of money or other property received from the Federal Deposit Insurance Corporation pursuant to sections 13(c), 15(c)(1), and 15(c)(2) of the Federal Deposit Insurance Act (12 U.S.C. 1821(f) and 1823(c)(1) and (c)(2)), regardless of whether any note or other instrument is issued in exchange therefor.”
Subsec. (b). Pub.L. 100-647, § 4012(b)(2)(C), substituted “association or bank” for “association”.
Subsec. (c). Pub.L. 100-647, § 4012(c)(1), added subsec. (c).
Subsec. (d). Pub.L. 100-647, § 4012(b)(2)(B), added subsec. (d).
1986 Amendments. Pub.L. 99-514, Title IX, § 904(b)(1), (c)(2)(A), Oct. 22, 1986, 100 Stat. 2385, as amended Pub.L. 100-647, Title IV, § 4012(a)(2), Nov. 10, 1988, 102 Stat. 3656, applicable to transfers after Dec. 31, 1989, in taxable years ending after such date, with exceptions, directed repeal of this section, and was repealed by Pub.L. 101-73, Title XIV, § 1401(b)(1), Aug. 9, 1989, 103 Stat. 549, effective Oct. 22, 1986, as if amendments made by such section had not been enacted.
Effective and Applicability Provisions
1990 Acts. Amendment by section 11704 of Pub.L. 101-508 shall take effect Nov. 5, 1990, see section 11704(b) of Pub.L. 101-508, set out as a note under section 56 of this title.
1989 Acts. Section 7841(e)(2) of Pub.L. 101-239 provided that: “The amendment made by this subsection [amending subsec. (b)(2) of this section] shall apply as if included in the amendments made by section 1401 of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 [Pub.L. 101-73].”
Section 1401(c)(3) of Pub.L. 101-73 provided that:
“(A) In general.--The amendments made by subsection (a)(3) [amending this section and repealing section 904(c)(2)(B) of Pub.L. 99-514, set out below] shall apply to any amount received or accrued by the financial institution on or after May 10, 1989, except that such amendments shall not apply to transfers on or after such date pursuant to an acquisition to which the amendment made by subsection (a)(1) [amending section 368(a)(3)(D) of this title] does not apply.
“(B) Interim rule.--In the case of any payment pursuant to a transaction on or after May 10, 1989, and before the date on which the Secretary of the Treasury (or his delegate) takes action in exercise of his regulatory authority under section 597 of the Internal Revenue Code of 1986 (as amended by subsection (a)(3)) [this section], the taxpayer may rely on the legislative history for the amendments made by subsection (a)(3) [amending this section] in determining the proper treatment of such payment.”
[Section 1401(c)(4) of Pub.L. 101-73 provided that: “The provisions of subsection (b)(1) [repealing section 904 of Pub.L. 99-514, other than subsection (c)(2)(B) thereof, relating to clarification of treatment of amounts excluded under this section] shall take effect on the date of the enactment of the Tax Reform Act of 1986 [Oct. 22, 1986].”]
[Section 1401(c)(5) of Pub.L. 101-73, provided that: “The amendment made by subsection (b)(2) [amending section 4012(c)(3) of Pub.L. 100-647, set out as a note under this section] shall take effect on the date of the enactment of the Technical and Miscellaneous Revenue Act of 1988 [Nov. 10, 1988].”]
1988 Acts. Section 4012(b)(2)(E) of Pub.L. 100-647 provided that: “The amendments made by this paragraph [amending the heading and subsecs. (a), (b) and (d) of this section] shall apply to any transfer--
“(i) after the date of the enactment of this Act [Nov. 10, 1988], and before January 1, 1990, unless such transfer is pursuant to an acquisition occurring on or before such date of enactment, and
“(ii) after December 31, 1989, if such transfer is pursuant to an acquisition occurring after such date of enactment and before January 1, 1990.”
Section 4012(c)(3) of Pub.L. 100-647, as amended Pub.L. 101-73, Title XIV, § 1401(b)(2), Aug. 9, 1989, 103 Stat. 549, provided that: “The amendments made by this subsection [enacting subsec. (c) of this section and provisions set out as a note under this section] shall apply to any transfer--
“(A) after December 31, 1988, and before January 1, 1990, unless such transfer is pursuant to an acquisition occurring before January 1, 1989, and
“(B) after December 31, 1989, if such transfer is pursuant to an acquisition occurring after December 31, 1988, and before January 1, 1990.
In the case of any bank or any institution treated as a domestic building and loan association for purposes of section 597 of the 1986 Code [this section] by reason of the amendment made by subsection (b)(2)(B) [enacting subsec. (d) of this section], the amendments made by this subsection shall also apply to any transfer before January 1, 1989, to which the amendments made by subsection (b)(2) [amending this section and enacting a provision set out as a note under this section] apply.”
1981 Acts. Section 246(c) of Pub.L. 97-34 provided that: “The amendment made by section 244 [enacting this section] shall apply to any payment made on or after January 1, 1981.”
Effective Date of Repeal
Pub.L. 99-514, Title IX, § 904(c)(2), Oct. 22, 1986, 100 Stat. 2385, as amended Pub.L. 100-647, Title IV, § 4012(a)(2), (c)(2), Nov. 10, 1988, 102 Stat. 3656, 3660, providing that repeal of this section applicable to transfers after Dec. 31, 1989, in taxable years ending after such date, with exceptions, and relating to clarification of treatment of amounts excluded under this section was repealed by Pub.L. 101-73, Title XIV, § 1401(a)(3)(B), (b)(1), Aug. 9, 1989, 103 Stat. 549.
Transfer of Functions
Federal Savings and Loan Insurance Corporation abolished and functions transferred, see Pub.L. 101-73, Title IV, §§ 401 to 406, Aug. 9, 1989, 103 Stat. 354 to 363, set out as a note under 12 U.S.C.A. § 1437.
Severability of Provisions
If any provision of Pub.L. 101-73 or the application thereof to any person or circumstance is held invalid, the remainder of Pub.L. 101-73 and the application of the provision to other persons not similarly situated or to other circumstances not to be affected thereby, see section 1221 of Pub.L. 101-73, set out as a note under section 1811 of Title 12, Banks and Banking.
Clarification of Prior Law
Section 1401(c)(7) of Pub.L. 101-73 provided that: “Any reference to the Federal Savings and Loan Insurance Corporation in section 597 of the Internal Revenue Code of 1986 [this section] (as in effect on the day before the date of the enactment of this Act [Aug. 9, 1989]) shall be treated as including a reference to the Resolution Trust Corporation and the FSLIC Resolution Fund”.
Annual Reports on Transactions in Which Federal Financial Assistance Provided
Pub.L. 101-73, Title XIV, § 1403, Aug. 9, 1989, 103 Stat. 551, which required the Secretary of the Treasury to submit annual reports to the Senate and to the Committee on Ways and Means of the House of Representatives on transactions with respect to which Federal financial assistance subject to this section was provided, terminated, effective May 15, 2000, pursuant to Pub.L. 104-66, § 3003, as amended, set out as a note under 31 U.S.C.A. § 1113. See, also, page 142 of House Document No. 103-7.
CODE OF FEDERAL REGULATIONS
Bridge banks and agency control, see 26 CFR § 1.597-4.
Effective date, see 26 CFR § 1.597-7.
Limitation on collection of income tax, see 26 CFR § 1.597-6.
Other rules, see 26 CFR § 1.597-3.
Taxable transfers, see 26 CFR § 1.597-5.
Taxation of federal financial assistance, see 26 CFR § 1.597-2.
Transitional rules for federal financial assistance, see 26 CFR § 1.597-8.
LIBRARY REFERENCES
American Digest System
Key Number System Topic No. 220.
Corpus Juris Secundum
CJS Internal Revenue § 413, Savings Institutions.
RESEARCH REFERENCES
Encyclopedias
Am. Jur. 2d Federal Taxation P 20477, Contributions to Domestic Building and Loan Associations and Banks Under Federal Financial Assistance (Ffa) Programs.
Am. Jur. 2d Federal Taxation P 20478, What is Federal Financial Assistance (Ffa).
Forms
Nichols Cyclopedia of Legal Forms Annotated § 52:9, Other Possible Tax Status of Credit Union.
Treatises and Practice Aids
Mertens: Law of Federal Income Taxation § 34A:3, Organizations Subject to Cooperative Treatment.
Mertens: Law of Federal Income Taxation § 29:162, Thrift Institutions.
Mertens: Law of Federal Income Taxation § 38:112, Banks and Trust Companies.
Mertens: Law of Federal Income Taxation § 45E:232, Tax Attributable to Amount Included as Dividend--Pro Rata Share.
NOTES OF DECISIONS
Agreements 2
Calculation of deduction 4
Damages 5
Estoppel 3
Proof of damages 6
Repeal of covered asset loss deduction 1
Tax on damages 7
1. Repeal of covered asset loss deduction
Congress's
retroactive abolition of built-in loss deduction for acquiring
institutions, which deprived acquiring institutions of substantial
part of benefit of their contract with government, constituted
breach of implied covenant of good faith and fair dealing by
government, although no statute expressly entitled acquiring
institutions to deduct built-in losses. Centex
Corp. v. U.S., C.A.Fed.2005, 395 F.3d 1283,
rehearing and rehearing en banc denied. Public
Contracts
345;
United
States
73(22)
2. Agreements
Provision
in assistance agreement that governed acquisition of failing thrifts
by financial institution, which allowed institution to seek
reimbursement from government for payments made to federal agency
that related to tax deductions that were subsequently disallowed,
did not provide exclusive remedy for government's breach of implied
covenant of good faith and fair dealing through enactment of
legislation that prevented institution from claiming reimbursed net
liabilities of failing thrifts as tax deductions, as provided by
agreement, and thus provision did not preclude government's
liability for damages arising from its breach. Local
Oklahoma Bank, N.A. v. U.S., C.A.Fed.2006, 452 F.3d 1371.
Public
Contracts
403;
United
States
74(3)
Proper
remedy for breach of contract which occurred when Congress
eliminated tax deduction for covered asset losses sustained by
financial institutions when they sold or wrote off certain assets of
failing thrifts acquired by them was to restore reduction in
reimbursement to institutions for covered asset losses by Federal
Savings and Loan Insurance Corporation (FSLIC), a reduction which
resulted from agreement to share tax deduction benefits with the
FSLIC. First
Nationwide Bank v. U.S., C.A.Fed.2005, 431 F.3d 1342.
Public
Contracts
416(3);
United
States
74(13)
Provision
of thrift bailout agreement that the best efforts clause of
agreement would not be “construed to include an obligation to
pay money, unless specifically required by the language of this
Agreement or to take impractical or unreasonable actions,” did
not preclude right to monetary damages based on claim of acquirer of
failing thrifts that government breached implied covenant of good
faith and fair dealing when Congress enacted legislation which
retroactively eliminated tax benefits of agreement. Temple-Inland,
Inc. v. U.S., Fed.Cl.2004, 59 Fed.Cl. 550.
Public
Contracts
416(3);
United
States
74(13)
Government
breached implied covenant of good faith and fair dealing in thrift
bailout agreement when Congress enacted the Guarini legislation in
1993 which retroactively eliminated tax deduction for covered asset
losses (CALs) sustained by acquirer when it disposed of assets of
failing thrifts; pursuant to agreement, acquirer was entitled to
deduct the losses and keep 75% of the tax savings, while government
took the remaining 25%, and government made implicit promise not to
exercise its taxing power to eliminate the means by which the
benefits were generated and thereby divert to itself one hundred
percent of the benefits. Temple-Inland,
Inc. v. U.S., Fed.Cl.2004, 59 Fed.Cl. 550.
Public
Contracts
345;
United
States
73(22)
Doctrine
of prior material breach did not bar financial institutions from
recovering on their claim that enactment of Guarini legislation in
1993 breached provision of assistance agreement allowing tax
deduction for covered asset losses; assuming that institutions
materially breached the agreement before the Guarini legislation,
conduct of the government in accepting performance since the breach
constituted election to continue the contract. First
Heights Bank, FSB v. U.S., Fed.Cl.2001, 51 Fed.Cl. 659,
affirmed 422
F.3d 1311.
Public
Contracts
351;
United
States
73(3)
3. Estoppel
Bank
which prevailed on claim that government breached contract when
Congress enacted the Guarini legislation in 1993 which retroactively
eliminated tax deduction for covered asset losses incurred in
acquisition of failing thrift was not estopped from asserting a
larger damages figure than that incorporated in prior tax return
filed by bank. National
Australia Bank v. U.S., Fed.Cl.2004, 63 Fed.Cl. 352,
affirmed in part, reversed in part and remanded 452
F.3d 1321,
motion denied 74
Fed.Cl. 435.
Estoppel
63
4. Calculation of deduction
Court
of Federal Claims did not abuse its discretion in adopting
government's methodology for calculating interest offset claim of
financial institution, in institution's Winstar-related
action alleging that government breached its contracts with passage
of legislation which disallowed covered asset loss deductions;
although clause in agreement provided that institution reserved
right to have its interest offset claim calculated according to its
methodology, government in subsequent clause reserved “right
to assert that the Interest Offset Claim should be computed in a
manner other than the manner in which [institution] has computed
it.” Local
Oklahoma Bank, N.A. v. U.S., C.A.Fed.2006, 452 F.3d 1371.
Public
Contracts
416(3);
United
States
74(13)
Government
did not establish that thrift holding company's figure of
$555,791,213 in lost covered asset loss (CAL) deductions should be
reduced by approximately $150 million, reducing damages for
government's breach of implied covenant of good faith and fair
dealing in thrift bailout agreement when Congress enacted the
Guarini legislation in 1993 which retroactively eliminated tax
deduction for covered asset losses (CALs), based on its assertion
that proper tax treatment of the write off of loans between thrift
and its subsidiaries required such reduction, as company was
entitled to base its claim on state of its closed tax returns.
Temple-Inland
Inc. v. U.S., Fed.Cl.2005, 68 Fed.Cl. 561.
Public
Contracts
415(8);
United
States
74(13)
5. Damages
Bank
established with reasonable certainty expectancy damages incurred as
result of United States' breach of its implied covenant of good
faith and fair dealing due to enactment of Guarini legislation,
which eliminated tax deductions promised to bank when it acquired
assets of failing thrift, despite United States' contention that
bank did not know tax basis for any of its covered assets, where tax
experts testified that gross book value for book purposes and tax
basis of asset were equivalent. National
Australia Bank v. U.S., C.A.Fed.2006, 452 F.3d 1321,
motion denied 74
Fed.Cl. 435.
Public
Contracts
415(8);
United
States
74(13)
Prior
settlement payment by Federal Deposit Insurance Corporation (FDIC)
did not include damages flowing from Guarini Legislation which
retroactively eliminated covered asset loss (CAL) deductions and
ensuing breach of contractual tax benefits; sections of settlement
dealt with covered asset gains, Guarini Legislation affected only
covered asset losses, and claimed CALs were distinct. First
Nationwide Bank v. U.S., C.A.Fed.2005, 431 F.3d 1342.
Public
Contracts
408;
United
States
74(6)
Private
acquiring institutions were not entitled to 100 percent of tax
savings from built-in loss deductions, as damages for government's
breach of assistance agreement, which originally was to be split
evenly between Federal Deposit Insurance Corporation (FDIC) and
those institutions, by termination agreement, which stated that if
claim was brought against government based upon enactment of
particular legislation, “the FDIC Manager shall not be
obligated to pay the expenses of such litigation and shall not be
entitled to share in any recoveries”; institutions were merely
entitled to keep entirety of any award they received from government
free from any claim by FDIC, rather than FDIC's share of savings.
Centex
Corp. v. U.S., C.A.Fed.2005, 395 F.3d 1283,
rehearing and rehearing en banc denied. Public
Contracts
416(3);
United
States
74(13)
Government
did not establish that thrift holding company failed to mitigate its
damages from government's breach of implied covenant of good faith
and fair dealing in thrift bailout agreement when Congress enacted
the Guarini legislation in 1993 which retroactively eliminated tax
deduction for covered asset losses (CALs), based on assertion that
holding company could have avoided the loss of at least $181.5
million of the deductions disallowed by accelerating deductions and
amending its pre-Guarini tax returns. Temple-Inland
Inc. v. U.S., Fed.Cl.2005, 68 Fed.Cl. 561.
Public
Contracts
415(8);
United
States
74(13)
Financial
institutions who prevailed on claim that the government breached
implied covenant of good faith and fair dealing when Congress
enacted the Guarini legislation in 1993 which retroactively
eliminated a tax deduction for covered asset losses (CALs) incurred
when they sold or wrote off assets of failing thrifts were entitled
to recover the net amount of the lost federal income tax benefit.
First
Heights Bank, FSB v. U.S., Fed.Cl.2003, 57 Fed.Cl. 162.
Public
Contracts
416(3);
United
States
74(13)
6. Proof of damages
Bank,
as successor in interest to thrift holding company, offered
sufficient evidence that it suffered $103,155,357 in lost tax
deductions as a result of government's breach of implied covenant of
good faith and fair dealing when Congress enacted the Guarini
legislation in 1993, which retroactively eliminated a tax deduction
for covered asset losses sustained by financial institutions when
they sold or wrote off assets of failing thrift acquired by them
under assistance agreement with the Federal Savings and Loan
Insurance Corporation (FSLIC); although bank could not produce an
asset-by-asset list of each asset's tax basis, aggregate figures
satisfied required legal standard for expectancy damages. National
Australia Bank v. U.S., Fed.Cl.2004, 63 Fed.Cl. 352,
affirmed in part, reversed in part and remanded 452
F.3d 1321,
motion denied 74
Fed.Cl. 435.
Public
Contracts
416(3);
United
States
74(11)
7. Tax on damages
Bank
which was entitled to damages for government's breach of assistance
agreement allowing it to take covered asset loss (CAL) tax
deductions which occurred when legislation was passed retroactively
repealing CAL deduction, was not also entitled to have the damages
award “grossed up” to reimburse it for income taxes it
anticipated paying on the principal award, as award of damages for
the government's breach would not constitute taxable income. Local
Oklahoma Bank, N.A. v. U.S., Fed.Cl.2004, 59 Fed.Cl. 713,
affirmed 452
F.3d 1371.
Public
Contracts
416(3);
United
States
74(13)
I.R.C. § 597, 26 U.S.C.A. § 597
Current through P.L. 113-31 approved 8-9-13
Westlaw. (C) 2013 Thomson Reuters. No Claim to Orig. U.S. Govt. Works.
END OF DOCUMENT
© 2013 Thomson Reuters. No Claim to Orig. US Gov. Works.
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Author | 13.8.3.1.V2 |
Last Modified By | Department of Treasury |
File Modified | 2013-09-16 |
File Created | 2013-09-16 |