SECTION 5. INFORMATION TO BE

INCLUDED IN REQUESTS FOR CONSENT UNDER § 1.1502–13(e)(3)

.01 Each of the items of information requested in this Section 5 must be addressed in the request for consent under § 1.1502–13(e)(3). If an item is not applicable, the letters “N.A.” should be inserted after that item. The presentation of the information should follow the format of this revenue procedure as closely as possible.

.02 Information needed in order to make a determination regarding a request for consent to treat some or all intercompany transactions on a separate entity basis:

1. The date the consolidated group elected to file consolidated returns.

2. The taxable year used by the consolidated group.

3. A calculation of the difference, for the consent year and for each of the two

26 CFR 601.201: Rulings and determination letters. (Also §§ 1502; 1.1502–13.)

Rev. Proc. 97–49