- 16 - and Woolford Realty Co. v. Rose, 286 U.S. 319 (1932)); cf. Gottesman & Co. v. Commissioner, 77 T.C. 1149, 1156 (1981) (“to the extent the consolidated return regulations do not mandate different treatment, corporations filing consolidated returns are to be treated as separate entities when applying other provisions of the Code”). Nor do the consolidated return regulations, as applicable here, change this result. Those regulations require that Peoples calculate its net income separately from Investments’ net income. See sec. 1.1502-11(a)(1), Income Tax Regs. (stating that taxable income is calculated for an affiliated group by taking into account the separate taxable income of each member of the group). Respondent has not identified, nor are we aware of, any provision in the consolidated return regulations that would require the tax-exempt obligations purchased and owned by Investments to be taken into account in the calculation of Peoples’ interest expense deduction. Nothing that we read in the statutes or in the consolidated return regulations directs us to ignore the separate existence of Investments and Peoples or otherwise to treat Investments’ self-purchased tax-exempt obligations as owned by Peoples for purposes of calculating the numerator as to Peoples. Congress knew how to require a taxpayer to take into account the assets of another taxpayer had Congress intended to include respondent’s “look-through” approach in the applicable statutes.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: March 27, 2008