SECTION 7. GROUPS WITH NO

YEARS BEFORE THE SERVICE ON JANUARY 8, 1996

If the consolidated group is not governed by Section 6, then it must satisfy the requirements in Section 7.01 and, as applicable, Sections 7.02 and 7.03.

.01 Filing the statement of election

and delivering copies of the statement of election .

(1) In general .

If the due date (including extensions) of the federal income tax return for the election year is later than July 1, 1996, the group must file the statement of election by attaching it to the timely filed federal income tax return for the election year. If the due date (including extensions) of the federal income tax return for the election year is on or before July 1, 1996, then, except as provided in Section 7.01(2) of this revenue procedure, the group must file the statement by attaching it to either the federal income tax return for the election year or an amended return for the election year, and the return or amended return must be filed on or before July 1, 1996.

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(2) Groups with one or more

affected years that have become years before the Service .

If one or more affected years have become years before the Service when the group files the statement of election, then, in lieu of attaching the statement to an original or amended return for the election year, the group must file the statement of election by delivering it to the Service personnel handling the earliest affected year that is then before the Service and by delivering copies of the statement to the Service personnel handling any other affected years that are then before the Service.

(3) Year before a federal court .

In addition to the requirements stated in Sections 7.01(1) and 7.01(2), if an affected year is before a federal court when the group files the statement of election, then, on the date the statement is filed, the group must deliver a copy of the statement to the lawyer representing the Government with respect to the year.

.02 Furnishing computations .

If the federal income tax return for an affected year is inconsistent with the single-entity election and if the affected year is before the Service when the group files the statement of election, computations necessary to support any adjustment in tax for the year must be delivered with the statement of election (or the copy of the statement) that is required under Section 7.01(2) of this revenue procedure.

.03 Filing other amended returns .

If the federal income tax return for an affected year is inconsistent with the single-entity election and if the affected year is not before the Service when the group files the statement of election, an amended return for the year containing a copy of the statement must be filed on or before July 1, 1996. If, on or before July 1, 1996, the year becomes a year before the Service, then, in lieu of filing an amended return, the group may satisfy the requirement in the preceding sentence by, not later than July 1, 1996, delivering to the Service

The group must file the statement of election with the Service personnel handling the earliest affected year before the Service. If other affected years are before the Service on the date the group files the statement of election, the group must also deliver copies of the statement to the Service personnel handling those years. In addition, if an affected year is before a federal court on the date the group files the statement of election, the group must deliver a copy of the statement to the lawyer representing the Government with respect to the year. The requirements in this Section 6.01 must be satisfied no later than March 8, 1996.

.02 Furnishing computations .

In the case of any affected year that is before the Service on the date the group files the statement of election, if the federal income tax return for the year is inconsistent with the singleentity election, then computations necessary to support any adjustment in tax must be delivered to the Service personnel handling the year.

If the year is before the Service on January 8, 1996, the computations must be delivered no later than March 8, 1996. If the year is not before the Service on January 8, 1996, but becomes a year before the Service prior to the filing of the statement of election, then the computations must be delivered no later than July 1, 1996.

.03 Filing amended returns .

In the case of any affected year that is not before the Service on the date the group files the statement of election, if the federal income tax return for the year is inconsistent with the single-entity election, then an amended return containing a copy of the statement of election must be filed on or before July 1, 1996. If the year becomes a year before the Service between the filing of the statement of election and July 1, 1996, then, in lieu of filing an amended return, the group may satisfy the requirement in the preceding sentence by, not later than July 1, 1996, delivering to the Service

personnel handling that year a copy of the statement of election and computations necessary to support any adjustment in tax.