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petitioner finds support for a consolidated calculation of the
adjustment. Petitioner further supplements this emphasis with
averments that such single-entity methodology is consistent with
the preemption principles espoused in the life-nonlife
consolidated return regulations, as well as with the historical
development of the AMT regulations.
Respondent, in contrast, begins broadly with the expressed
intent of Congress in enacting the AMT. Respondent alleges that
Congress manifested an intent to have the loss limitations of
section 1503(c) apply in the AMT regime through observance of a
parallel system. Respondent therefore seeks to integrate the
subgroup structure of the calculation directed in the life-
nonlife consolidated return regulations into the AMT context. In
particular, respondent contends that, in view of the relationship
between the book income adjustment and the ATNOL deduction
revealed in section 56, the subgroup method is necessary to
respect the section 1503(c) loss limits.
III. Analysis
A. General Implications of the Book Income Adjustment
Provisions
As a general proposition, we agree with petitioner that the
language employed in section 56(f) and attendant regulations
reflects a consolidated approach to the book income adjustment.
The statutory and regulatory provisions regarding the adjustment
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