- 21 - a separate-member, approach should be used in computing product liability loss for purposes of section 172(j)(1). In that context, the Supreme Court stated: Thus, it is true, as the Government has argued, that “[t]he Internal Revenue Code vests ample authority in the Treasury to adopt consolidated return regulations to effect a binding resolution of the question presented in this case.” * * * To the extent that the Government has exercised that authority, its actions point to the single-entity approach as the better answer. To the extent the Government disagrees, it may amend its regulations to provide for a different one. [Id. at 838.] Honeywell Inc. v. Commissioner, supra at 631-633, involved the Commissioner’s contention that certain depreciation regulations were not intended to cover the taxpayer’s sales of leased computers to the respective lessees. We rejected as unpersuasive the Commissioner’s reliance on caselaw “as establishing a ‘concept’ to override the express language of his regulations”. Id. at 635. Petitioner draws the parallel that respondent should not be permitted to invoke the “concept” of the life-nonlife subgroup to defeat the language of the section 56(f) regulations. We agree that, notwithstanding various factual and substantive distinctions, these broad principles from United Dominion Indus., Inc. v. United States, supra, and Honeywell Inc. v. Commissioner, supra, ring true here. While it may be said that the loss limits of section 1503(c) must be respected in calculating the AMT of a life-nonlife group, it does not follow that the explicit book income adjustment rulesPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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