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must be rejected. As petitioner emphasizes, appropriate
allocation of the adjustment, where necessary, can accommodate
these limitations in arriving at ATNOL or AMTI within the context
of the otherwise mandated consolidated approach.
(Although it is unnecessary here to reach the mechanics of
an appropriate allocation, we note that the idea of allocation of
consolidated adjustments is not foreign to the consolidated
return regime. As regards the book income adjustment in
particular, commentators have observed that allocation of the
consolidated adjustment could be required in situations involving
groups other than life-nonlife entities, such as where a member
joins or departs from a consolidated group, and have suggested
possible allocation methods. See Sair & Axelrod, “Issues and
Uncertainties in Consolidated AMT”, 305 PLI/Tax 141, 166-168
(1990) (advancing two potential allocation strategies:
Allocation based on each corporation’s relative book income as
compared to the total net book income and pro rata allocation
based on book income adjustment amounts). With respect to
consolidated adjustments besides that for book income, certain
regulations provide for allocation or attribution to particular
group members. For instance, petitioner cites sections 1.1502-
21(b) and 1.1502-55(h)(4)(iii)(B)(1), Income Tax Regs.,
promulgated after the years relevant here, as prescribing rules
for determining, respectively, the portion of a consolidated NOL
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