Result. (A) P must compute its taxable income for year 1 without taking into ac- count the $50x dual consolidated loss, pursu- ant to § 1.1503(d)–4(c)(2). Such amount con- sists of a pro rata portion of the expenses that were taken into account in calculating the year 1 dual consolidated loss. Thus, the items of the dual consolidated loss that are not taken into account by P in computing its taxable income are as follows: $25x of xxx- ary expense ($75x/$150x × $50x); $16.67x of re- search and experimental expense ($50x/$150x × $50x); and $8.33x of interest expense ($25x/ $150x × $50x). The remaining amounts of each of these items, together with the $100x of sales income, are taken into account by P in computing its taxable income for year 1 as follows: $50x of salary expense ($75x ¥ $25x);
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