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reflect the income tax liability and the various
factors necessary for the determination of such
liability, and in order to prevent avoidance of such
tax liability.
Furthermore, if a consolidated return was made, the tax was
determined, computed, assessed, collected, and adjusted in
accordance with the regulations under section 1502 prescribed
before the last day prescribed by law for the filing of such
return. See sec. 1503(a).
Section 1.1502-2, Income Tax Regs., explained how a
consolidated group determined its tax liability. It provided, in
relevant part, as follows:
The tax liability of a group for a consolidated
return year shall be determined by adding together--
(a) The tax imposed by section 11 on the
consolidated taxable income for such year (see
[section] 1.1502-11 for the computation of consolidated
taxable income); * * *
Section 1.1502-11, Income Tax Regs., provided, in relevant
part, as follows:
(a) In general. The consolidated taxable income
for a consolidated return year shall be determined by
taking into account--
(1) The separate taxable income of each
member of the group (see [section] 1.1502-12
for the computation of separate taxable
income); * * *
Section 1.1502-12, Income Tax Regs., provided, in relevant
part, as follows:
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