P Corporation owns all the stock of S1 and S2 Corporations, and the group has filed consolidated tax returns on a calendar year basis for several years. In the current year (Year 1), S2 sells to S1 for $90,000 land S2 had purchased for $75,000. On December 31 of Year 2, S1 sells the land to a third party for $91,000. On January 18 of Year 3, P sells all of its S2 stock to a third party for a sales price equal to P€™s basis in the S2 stock. The consolidated group members report the following amounts of taxable income and loss (before deducting any NOLs or applying the matching and acceleration rules):

Assume that the group elects to forego the carryback period for the Year 2 consolidated NOL.
a. Determine the amount of NOL available for S2€™s Year 3 separate tax return.
b. Assume the same facts as in Part a except S1€™s land sale to a third party for $91,000 occurred on January 1 of Year 3. Determine the amount of NOL available for S2€™s Year 3 separate tax return.

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Taxable Income (Loss) Group Member Year 2 S165,000 $(30,000) 120,000 (20,000) 140,000)000 S1 S2 consolidated taxable income or loss before deducting any NOLs or applying the matching and acceleration rules 5 이 543 0001 a Pertains to January 1 through January 18 of Year 3.