WESTERN FEDERAL SAV. AND LOAN ASS'N v. C.I.R.

No. 88-2001.

880 F.2d 1005 (1989)

WESTERN FEDERAL SAVINGS AND LOAN ASSOCIATION, Respondent, v. COMMISSIONER OF INTERNAL REVENUE, Petitioner.

United States Court of Appeals, Eighth Circuit.

Decided July 27, 1989.


Attorney(s) appearing for the Case

Bruce Ellisen, Washington, D.C., for petitioner.

Harlan Stamper, Kansas City, Mo., and Richard L. Bacon, Washington, D.C., for respondent.

Before JOHN R. GIBSON and FAGG, Circuit Judges, and HEANEY, Senior Circuit Judge.


JOHN R. GIBSON, Circuit Judge.

The Commissioner of Internal Revenue appeals from a United States Tax Court decision determining that Western Federal Savings and Loan Association did not receive taxable income as a result of a stock dividend from the Federal Home Loan Bank of Des Moines (the "Des Moines district bank"). As a member savings institution, Western was obligated to maintain a certain capital stock ownership in the Des Moines district bank. On December 31...

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