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Cougar, Jaguar, and Ocelot Corporations have filed on a consolidated, calendar year basis for many years. At the beginning of the tax year, the group

Cougar, Jaguar, and Ocelot Corporations have filed on a consolidated, calendar year basis for many years. At the beginning of the tax year, the group elects to de-consolidate. The groups $6 million NOL carryforward can be traced in the following manner: one-half to Cougars operations and one-quarter each to Jaguars and Ocelots. How will Ocelot treat the NOL on its separate tax return?

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