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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