Parent Corporation,SubOne,and SubTwo have filed consolidated returns since 2008.All of the entities were incorporated in 2007.None of the group members incurred any capital gain or loss transactions during 2007-2010,nor did they make any charitable contributions.Taxable income computations for the members are listed below.
* Separate return year.
** Consolidated return year.
a.How much of the 2009 loss is apportioned to SubOne and SubTwo? How is this loss treated in generating a refund of prior tax payments?
b.Why would Parent consider electing to forgo the carryback of the 2009 consolidated NOL?
c.In this light, analyze the election to consolidate.
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