Parent corp, Sub one, and Sub two filed consolidated returns since 2014, the year in which all of the entities were incorporated. None of the members incurred any capital gain or loss transactions during 2014-2017, nor did they make any charitable contributions. Taxable income computations for the members are listed below.

On the first day of the 2024 tax year, a non-US investor purchases all of the stock of Sub two. How much of the 2023 consolidated loss can be applied to Sub Two's 2024 income?

The answer is Sub Two can take $53,333 of the $80,000 loss, calculdated as 120000/180000 x 80000 = 53,333.

My question is simple, where did the 180,000 denominator come from? I am stumped on that. thank you for your help.