ENTITY ORGANIZED UNDER AUTHORITY OF HOME LOAN BANK BOARD IS EXEMPT FROM THE COMMUNICATIONS EXCISE TAX.

UIL Number(s) 4251.00-00

                                             Date: May 25, 1989

X was organized under the authority of the Federal Home Loan Bank Board, as provided by the Federal Home Loan Bank Act of 1932, Pub. L. No. 304, 72nd Cong., 1st Sess. (1932), 12 U.S.C. section 1421 (1982) et seq. Although the shareholders of X are private savings and loan institutions, the Federal Government, through the Federal Home Loan Bank Board, rather than its shareholders exercises control over the policies of X.

Section 1433 of Title 12 U.S.C. (1982) provides, in part, that the bank, including its franchise, its capital, reserves, and surplus, its advances, and its income, shall be exempt from all taxation now or hereafter imposed by the United States, by any Territory, dependency, or possession thereof, or by any State, county, municipality, or local taxing authority; except that any real property of the bank shall be subject to State, Territorial, county, municipal, or local taxation to the same extent according to its value as other real property is taxed.

Accordingly, X is exempt from the communications tax imposed by section 4251(a) of the Code. Please note that the appropriate administrative official of X is responsible for collecting the tax from the individuals using the facilities and services for their personal or private business. The official will also be responsible for filing the prescribed tax returns and reporting and paying the tax so collected to the district director for the district in which is located the principal place of business of the telecommunications company furnishing the facilities and services.

This ruling is directed only to the taxpayer who requested it. Section 6110(j)(3) of the Code provides that it may not be used or cited as precedent.

                                   Sincerely yours,