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PACIFIC FIRST FEDERAL SAV. BANK v. C.I.R.

No. 91-70116.

961 F.2d 800 (1992)

PACIFIC FIRST FEDERAL SAVINGS BANK, Petitioner-Appellee, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided February 7, 1992.

As Amended on Denial of Rehearing and Rehearing May 21, 1992.

Attorney(s) appearing for the Case

Bruce R. Ellisen, Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellant.

John F. Coverdale, Fried, Frank, Harris, Shriver & Jacobson, Washington, D.C., for petitioner-appellee.

Before WALLACE, Chief Judge, HUG and RYMER, Circuit Judges.

As Amended on Denial of Rehearing and Rehearing En Banc May 21, 1992.

WALLACE, Chief Judge:

The Commissioner of Internal Revenue (Commissioner) appeals the tax court's decision that Treasury Regulation § 1.593-6A(b)(5)(vi), (vii) is invalid because it does not implement the congressional mandate in a reasonable manner. The tax court had jurisdiction pursuant to I.R.C. §§ 6214, 7442. (All references are to the Internal Revenue Code of 1954 (Code...

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