- 11 - (canons of statutory construction apply to interpretation of Treasury regulations); Whelan v. United States, 208 Ct. C1. 688, 529 F.2d 1000, 1002-1003 (1976) (canons of statutory construction used to interpret administrative regulations). The consolidated return regulations are built on the premise that members of a consolidated group are a single economic entity with regard to intercompany transactions and distributions and that resulting gains or losses are given effect only when the transferred property, or stock of the transacting member, leaves the consolidated group. See also secs. 1.1502-13 & 1.1502-14, Income Tax Regs.; see generally 3 Bittker & Lokken, Federal Taxation of Income, Estates and Gifts, par. 90.5, at 90-48 (2d ed. 1991): The basic concept underlying * * * [the consolidated return] provisions is that the consolidated group is * * * a single taxable enterprise whose tax liability ought to be based on its dealings with outsiders rather than on intragroup transactions. This single taxpayer concept lies at the heart of the treatment of intercompany transactions, which, with some exceptions to prevent tax avoidance, are eliminated in computing the group’s consolidated taxable income. Petitioner’s interpretation of section 1.1502-14(d)(4)(i)(c), Income Tax Regs., conflicts with this framework. At the time AVCO redeemed its note from Paul Revere, both were members of the Textron group and both remained members as of the end of the 1987 taxable year. There were no “dealings with outsiders” that wouldPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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