Applicability of the Normalization Requirements of the Internal Revenue Code to Consolidated Tax Savings Adjustments : Scheduled for a Hearing Before the Subcommittee On Select Revenue Measures of the Committee On Ways And Means On September 11, 1991 Jcx-

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sec. 1.1502-33). The Code and the consolidated return regulations provide methods for allocating and (continued) intercompany sales if a regulated utility purchases property from an affiliate pursuant to an arrangement that had a significant effect on the rates the utility may charge and the public utility commission has accepted or approved the accounting for such arrangement. The special rule is effective for closing agreements requested before November 16, 1966 (Treas. Reg. sec. 1 . 1502-13 ...( j )) .
Apparently the special rule was designed to allow certain telephone companies to continue to account for certain acquisitions of property from an nonregulated affiliate in a manner consistent with an arrangement in effect before promulgation of the 1966 consolidated return regulations. See, Fred W. Peel, Consolidated Tax Returns , sec. 13.05 (3d ed.) .
^^ See Rev. Proc. 91-11, 1991-6 I.R.B. 9, and Rev. Proc.
91-39, 1991-27 I.R.B. 11, for a description of the procedures that taxpayers may follow to obtain such consent.


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