Intermet Corporation & Subsidiaries - Page 16

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          regulations as promulgated by the Commissioner.  Sec. 1501.  As             
          we see it, petitioner's position ignores those regulations.                 
          Section 1.1502-21A(f), Income Tax Regs., provides the exclusive             
          method for computing the NOL of a consolidated group.  The                  
          computation of the CNOL under section 1.1502-21A(f), Income Tax             
          Regs., begins with the computation of each member's separate                
          taxable income under section 1.1502-12, Income Tax Regs.                    
          Accordingly, the CNOL is not computed purely on a consolidated              
          basis.  Moreover, as discussed supra at 12, SLL's are not treated           
          on a consolidated basis under the consolidated return                       
          regulations.  Similarly, there is no provision in the Code for a            
          consolidated SLL.11  As neither the Code nor the regulations                
          direct that SLL's are to be treated on a consolidated basis, and,           
          in light of the general principle that deductions are construed             
          narrowly, INDOPCO, Inc., v. Commissioner, 503 U.S. 79, 84 (1992);           
          Commissioner v. National Alfalfa Dehydrating & Milling Co., 417             
          U.S. 134, 149 (1974), we must reject petitioner's position.  See,           
          e.g., Amtel Inc. v. United States, supra at 602.                            
               Petitioner contends that its position is in harmony with the           
          underlying purpose of the consolidated return regulations, which            
          is to tax an affiliated group of corporations as a single                   


          11   By contrast, Congress has directed single entity treatment             
          for purposes of sec. 172 with respect to corporate equity                   
          reduction interest loss as defined in sec. 172(h).  See sec.                
          172(h)(4)(C).                                                               




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