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after the transaction in question, petitioner no longer had any
interest in its former glass business; LOF Glass operated as a
subsidiary of Pilkington Holdings. Thus, if section 47 were the
only provision involved in this case, this lack of retained
interest would be fatal to petitioner's position herein. Blevins
v. Commissioner, 61 T.C. 547 (1974); Aboussie v. Commissioner, 60
T.C. 549 (1973), affd. without published opinion 504 F.2d 758
(5th Cir. 1974); Soares v. Commissioner, 50 T.C. 909 (1968);
Purvis v. United States, 73-1 USTC par. 9157 (N.D. Ga. 1972).
However, the transactions herein took place in the
consolidated return context, which provides a different frame of
reference. Paragraph (f) of section 1.1502-3, Income Tax Regs.,
deals with early dispositions of section 38 assets of a member of
a consolidated group; subparagraph (2) of paragraph (f) provides:
(2) * * * a transfer of section 38 property from
one member of the group to another member of such group
during a consolidated return year shall not be treated
as a disposition or cessation within the meaning of
section 47(a)(1). If such section 38 property is
disposed of, or otherwise ceases to be section 38
property * * * before the close of the estimated useful
life * * *, then section 47(a)(1) or (2) shall apply
* * *
Subparagraph (3) of paragraph (f) provides:
(3) Examples. The provisions of this paragraph
may be illustrated by the following examples:
Example (1). P, S, and T file a consolidated
return for calendar year 1967. In such year S places
in service section 38 property having an estimated
useful life of more than 8 years. In 1968, P, S, and T
file a consolidated return, and in such year S sells
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