Based on the fact pattern and tax research, the following questions should be answered:
1. Which corporations are included in the affiliated group? In the controlled group?
2. What income is included in the various tax returns?
3. How is the allocation of the income between tax years made if the books are not closed on the sale or acquisition dates?
4. If no special allocations are made, what portion of the reduced tax rate benefits can be claimed in the current year by the affiliated group? In future years?