Two members of an expanded affiliated group (EAG), which do not file a consolidated Federal tax return, have positive QPAI. Dane, Inc., has taxable income, but Sloane, Inc., has a $230,000 net operating loss that offsets Dane’s taxable income

(and reduces any DPAD). However, the NOL could be carried back or forward to another tax year and reduce the EAG member’s QPAI again, thus reducing the EAG’s taxable income a second time. Advise the CFO of Dane as to this problem.