Put owned all of the stock of Call when the two corporations were formed a decade ago. The group immediately elected to file on a consolidated basis.

Now Call's management team has purchased the company from the parent and intends to carry on and expand the business into new markets.

When Call left the Put consolidated group, the group held a $5 million NOL carry forward, $2 million of which was attributable to Call's operations under formulas used by all of the parties. Call will generate $700,000 in taxable income on each of its first five years' worth of separate returns.

Advise Call as to who "owns" the carryforwards after the corporate division.