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other instances, separate computation of consolidated partial
LICTI (or loss from operations) and nonlife consolidated taxable
income (or loss) “does not affect the usual rules in secs.
1.1502-0--1.1502-80 unless this section provides otherwise.”
Sec. 1.1502-47(r), Income Tax Regs.
Hence, the preemption rules are by their terms limited to
other regulations promulgated under section 1502 and have no
direct applicability here. In this connection, it is noteworthy
that the AMT regulations were promulgated after those for life-
nonlife groups. Yet no provisions were put in place to specify
unique treatment for these insurance entities, although the
Commissioner had been made aware of the issue by a comment
received after issuance of temporary AMT regulations. See Field
Serv. Adv. Mem. TR-45-1815-95 (Apr. 10, 1996) (discussing events
leading up to the issuance of the final AMT regulations). Nor
were the explicit preemption directives in section 1.1502-47,
Income Tax Regs., augmented to bear upon regulations other than
those promulgated under section 1502. Given this scenario, we
find merit in petitioner’s analogy of the present situation
generally to cases such as United Dominion Indus., Inc. v. United
States, 532 U.S. 822 (2001), and Honeywell Inc. v. Commissioner,
87 T.C. 624 (1986).
In United Dominion Indus., Inc. v. United States, supra at
824-825, the Supreme Court held that a single-entity, rather than
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