concurring: Although I concur in the majority’s result, for the reasons expressed in my dissenting opinions in Pacific First Fed. Sav. Bank v. Commissioner, 94 T.C. 101, 117 (1990), and Georgia Fed. Bank v. Commissioner, 98 T.C. 105, 121 (1992), I continue to regard the questioned regulation as valid.
Parker, Jacobs, Wright, Parr, and Ruwe, JJ., agree with this concurring opinion.