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to be made on consolidated returns are replete with singular
references to “the taxpayer”, “a taxpayer”, “the book income
adjustment”, “its consolidated net book income”, “its pre-
adjustment alternative minimum taxable income”, and so forth.
E.g., sec. 56(f)(2)(C)(i); sec. 1.56-1(a)(3), Income Tax Regs.
The items to be compared in calculating the adjustment, i.e.,
consolidated preadjustment AMTI and consolidated adjusted net
book income, likewise are defined in terms that suggest a unified
treatment.
Consolidated preadjustment AMTI is determined by starting
with “the taxable income of the consolidated group for the
taxable year”. Sec. 1.56-1(b)(3)(iii), Income Tax Regs. This
terminology implies the regular taxable income of the full
consolidated group. Similarly, consolidated adjusted net book
income is derived from the applicable financial statement of the
common parent. Sec. 1.56-1(b)(3)(i) and (ii), and (c)(5)(i),
Income Tax Regs. Again the language points to a single
controlling document, and a subgroup approach could create an
apparent conflict with this inference. Absent an entity standing
in the relation of “common parent” to a particular subgroup, the
subgroup methodology is not analogous to that directed in the
regulations.
Moreover, Example 4 offers a numerical illustration in which
the book income and preadjustment AMTI of D and E are compared on
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