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year nonlife consolidated NOL and for nonlife consolidated net
operating and capital loss carrybacks and carryovers. Sec.
1.1502-47(h), Income Tax Regs.; see also secs. 1.1502-11, 1.1502-
12, 1.1502-21A, 1.1502-22A, Income Tax Regs. Consolidated
partial LICTI comprises the separate gross income and deductions
of life members and is reduced by life loss carrybacks and
carryovers from other years. Secs. 801-812, 818(e); sec. 1.1502-
47(k) and (l), Income Tax Regs. Nonlife consolidated taxable
income may then be set off by life losses and consolidated
partial LICTI by nonlife losses in accordance with the rules set
forth, respectively, in section 1.1502-47(n) and (m), Income Tax
Regs. Limitations reflected in section 1.1502-47(m), Income Tax
Regs., implement the mandate of section 1503(c).
The life-nonlife regulations additionally provide that other
consolidated return principles apply unless preempted by
inconsistent provisions in section 1.1502-47, Income Tax Regs.
Sec. 1.1502-47(q), Income Tax Regs. (“The rules in this section
preempt any inconsistent rules in other sections (sec. 1.1502-1
through sec. 1.1502-80) of the consolidated return
regulations.”); sec. 1.1502-47(r), Income Tax Regs. (“The fact
that this section treats the life and nonlife members as separate
groups in computing, respectively, consolidated partial LICTI (or
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Last modified: May 25, 2011