X Co. owns 100% of T Co. P Co. owns 100% of S Co. Both groups are affiliated groups which file consolidated tax returns. X has a NOL carryover of 100. P has a NOL carryover of 100. T and S have no NOL's. T has assets which consist of equipment with a FMV of 100, a cost basis of 75 and an adjusted basis of 50. P purchases 100% of X's T stock for 90 cash in one transaction. Assume X had a basis of 80 in its T stock.

What consequences if s.338 is elected?

Is there any further election which could change this result?