Rev. Rul. 54-520

Sections 461-465 of the Internal Revenue Code of 1939 relate to the privileges accorded acquiring corporations, as defined in section 461 of the Code, to use the base period experience of their component corporations if such use would result in a greater excess-profits credit than otherwise. The unused excess-profits credit of a component corporation is not a factor in the determination of an acquiring corporation's average base period net income computed with reference to section 462(b) of the Code relating to the method of recomputation of an acquiring corporation's excess-profits net income. Nor is it a factor in determining the adjusted excess-profits net income of the acquiring corporation, determined under the provisions of section 431 of the Code.