Turner Broadcasting System, Inc. and Subsidiaries - Page 32

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               shall not apply to restore that deferred loss and that loss            
               shall never be restored to the selling member.                         
                    (7) Basis adjustment and holding period.  If paragraph            
               (c)(6) of this section precludes a restoration for property,           
               then the following rules apply:                                        
                         (i) On the date the selling member                           
                    ceases to be a member, the owning member's                        
                    basis in the property shall be increased by                       
                    the amount of the selling member's unrestored                     
                    deferred loss at the time it ceased to be a                       
                    member ("increase amount").  [Emphasis                            
                    added.]                                                           

               The 1984 temporary regulation does not explicitly contain a            
          definition of what constitutes a sale between members of a                  
          controlled group.  However, it does generally incorporate section           
          1.1502-13, Income Tax Regs., of the consolidated return                     
          regulations that deal with "deferred intercompany transactions".            
          These regulations are said to apply, except as otherwise provided           
          in the 1984 temporary regulation.  No express provision can be              
          found in the 1984 temporary regulation that defines the scope of            
          transactions covered other than the reference to deferred                   
          "intercompany transactions".  The term "intercompany                        
          transactions" is not itself defined in the 1984 temporary                   
          regulation.  However, section 1.1502-13, Income Tax Regs., which            
          is referred to and made applicable by the 1984 temporary                    



               27(...continued)                                                       
                    when either the selling member or the member                      
                    which owns the property ceases to be a member                     
                    of the group;                                                     




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