SNOLSenior Naval Officer, Landings (US Navy)
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But the Fourth Circuit rejected the IRS's attempt to apply the STI rules for determining each member's separate NOL (SNOL) and instead applied the rules under Treas.
The difference between the STI approach proposed by the IRS and the SNOL employed by the Fourth Circuit is that STI does not take into account each member's contribution to items such as consolidated net capital gain or loss, consolidated section 1231 loss, consolidated charitable contribution deduction, or the consolidated dividends received deduction.
Table 1: Acronymns Used in This Article BIG = built-in gain BIL = built-in loss CNOL = consolidated net operating loss CNOLCO = consolidated net operating loss carryover CRY = consolidated return year CTI = consolidated taxable income FMV = fair market value NOL = net operating loss NOLCO = net operating loss carryover NUBIG = net unrealized built-in gain NUBIL = net unrealized built-in loss PCM = parent change method SM = supplemental method SNOL = separate net operating loss SRLY = separate return limitation year SRY = separate return year
1.1502-21T(b)(2) requires that any CNOL be apportioned to each member that had an SNOL in the year in which the CNOL was created.