- 23 -
attributable to particular group members and the contribution of
a member to a consolidated minimum tax credit limitation.)
C. Conclusion
To summarize, there exists both insufficient statutory or
regulatory support for divergence from the consolidated approach
reflected in the book income adjustment provisions and a
reasonable means through allocation to accommodate the section
1503(c) limits without resort to a subgroup approach. In
reaching this conclusion, we have considered all points raised by
the parties and, to the extent not addressed herein, they are
cumulative, irrelevant, or not appropriate for further discussion
because not presented by the facts before us. Accordingly, we
hold that, in the context of a life-nonlife consolidated return,
the AMT book income adjustment is to be made using a consolidated
approach, with a single adjustment for the entire group.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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