State Farm Mutual Automobile Insurance Company and Subsidiaries - Page 14




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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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