P Corporation operates six automotive service franchises in a metropolitan area. The service franchises have been a vast success in their first three years of operation, an P's annual taxable income exceeds $600,000. J Corporation owns real estate related with the six service franchises. P leases its automotive service franchise locations from J. J reports large interest and MACRS depreciation deductions because of a highly leveraged, capital intensive operation. As a result, J has reported NOLs in its first 3 years of operation. P and J file separate tax returns. Carol owns 100 percent of both corporations. Carol sees the idea for the automotive service franchise chain starting to really prepare and expects to add six more locations in each of the next two years. Because of the rapid expansion that is planned, she feels that she has outgrown her father's accountant and requires having new ideas to help her save tax dollars so she will reinvest more money in the business.