Problem
Cougar, Jaguar, and Ocelot Corporations have filed on a consolidated, calendar year basis for many years. At the beginning of the tax year, the group elects to de-consolidate. The group's $6 million NOL carryforward can be traced in the following manner: one-half to Cougar's operations and one-quarter each to Jaguar's and Ocelot's. How will Ocelot treat the NOL on its separate tax return?