- 3 - Equipment) of Rev. Proc. 87-56, 1987-2 C.B. 674, should be classified as class 57.0 property. Held: Rev. Proc. 87-56 carries forward the pattern established in Rev. Proc. 62-21, 1962-2 C.B. 418; the priority rule of Rev. Proc. 62-21 is implicit in Rev. Proc. 87-56: Asset guideline class 00.11 takes precedence over asset guideline class 57.0. V. P claims that, in determining the portion of the UBC affiliated group’s consolidated net operating loss (NOL) that is attributable to bad debt deductions of bank members, and is, thus, subject to the special 10-year carryback rule of sec. 172(b)(1)(L), I.R.C., it can apply the special loss ordering rule of sec. 172(l)(1), I.R.C., to the consolidated NOL of both bank and nonbank members. Held: The consolidated return regulations contemplate that the consolidated NOL is comprised of the separate taxable income, including separate NOL, of each member, and the special ordering rules of sec. 172(l)(1), I.R.C., apply to a bank not between a bank member and a nonbank member of an affiliated group. Walter A. Pickhardt, Mark Hager, and Scott G. Husaby for petitioners. Jack Forsberg, Tracy Martinez, Robert M. Ratchford, and David L. Zoss, for respondent. OPINION HALPERN, Judge: Norwest Corp. (Norwest), a Delaware corporation, is the petitioner in each of these consolidated cases. Norwest is the petitioner by virtue of being the successor in interest to various other corporations. When necessary for clarity, we shall refer by name to Norwest or one or the other of those predecessor corporations. Otherwise, wePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011