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of section 1503(c) is to direct that items of income and
deduction relevant to operating loss be determined on a subgroup
basis, it follows that this framework should be maintained not
only up to (as in petitioner’s computations) but through (as in
respondent’s computations) calculation of the book income
adjustment in order to arrive at separate ATNOL figures that
parallel the separate loss amounts derived under the regular tax
system.
The principal difficulty with this approach, however, is
that it proposes to override the explicit language of the book
income adjustment regulations in absence of any textual
expression of preemption. While legislative history indicates
that the loss limits of section 1503(c) are to apply for AMT
purposes, no methodology for doing so was directly specified or
mandated. Use by Congress of “parallel” in this context is not a
compelling substitute for express rules.
As previously indicated, the life-nonlife consolidated
return regulations contain several provisions addressing the
interaction between those rules in section 1.1502-47, Income Tax
Regs., and other consolidated return regulations promulgated
under section 1502. Secs. 1.1502-47(a)(4), (q), (r), Income Tax
Regs. The life-nonlife sections are expressly declared to
preempt inconsistent rules in sections 1.1502-1 through 1.1502-
80, Income Tax Regs. Sec. 1.1502-47(q), Income Tax Regs. In
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