Rev. Rul. 54-364

The issuance of income tax Regulations 118 to supersede Regulations 111 does not, of itself, amend the consolidated return regulations and, therefore, the continued filing of consolidated returns has not been made less advantageous to affiliated groups as a class. Accordingly, affiliated groups which filed consolidated returns in prior years may not elect to file separate returns when filing their first returns due after September 26, 1953, the date Regulations 118 were issued, solely because of such issuance. Cf. Rev. Rul. 152, C. B. 1953-2, 184. For taxable years with respect to which the Internal Revenue Code of 1954, Public Law 591, Eighty-Third Congress, approved August 16, 1954, will apply, see Revenue Ruling 54-365, page 13, this Bulletin.