- 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, we
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