[Code of Federal Regulations]
[Title 26, Volume 12]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.1502-6]

[Page 256]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.1502-6  Liability for tax.

    (a) Several liability of members of group. Except as provided in 
paragraph (b) of this section, the common parent corporation and each 
subsidiary which was a member of the group during any part of the 
consolidated return year shall be severally liable for the tax for such 
year computed in accordance with the regulations under section 1502 
prescribed on or before the due date (not including extensions of time) 
for the filing of the consolidated return for such year.
    (b) Liability of subsidiary after withdrawal. If a subsidiary has 
ceased to be a member of the group and in such cessation resulted from a 
bona fide sale or exchange of its stock for fair value and occurred 
prior to the date upon which any deficiency is assessed, the 
Commissioner may, if he believes that the assessment or collection of 
the balance of the deficiency will not be jeopardized, make assessment 
and collection of such deficiency from such former subsidiary in an 
amount not exceeding the portion of such deficiency which the 
Commissioner may determine to be allocable to it. If the Commissioner 
makes assessment and collection of any part of a deficiency from such 
former subsidiary, then for purposes of any credit or refund of the 
amount collected from such former subsidiary the agency of the common 
parent under the provisions of Sec. 1.1502-77 shall not apply.
    (c) Effect of intercompany agreements. No agreement entered into by 
one or more members of the group with any other member of such group or 
with any other person shall in any case have the effect of reducing the 
liability prescribed under this section.

[T.D. 6894, 31 FR 11794, Sept. 8, 1966, as amended by T.D. 9002, 67 FR 
43540, June 28, 2002]