Rev. Rul. 67-334

Advice has been requested whether, in the circumstances described below, an affiliated group must file its declaration of estimated tax on a consolidated basis for the calendar year 1967.

A corporation and its subsidiaries have filed consolidated income tax returns for the calendar years 1965 and 1966. Separate declarations of estimated tax have been filed for 1965 and 1966 by each member.

Section 1.1502-5 of the Income Tax Regulations provides, effective for taxable years beginning after December 31, 1965, that if a group fils a consolidated return for two consecutive taxable years, it shall file its declaration of estimated tax on a consolidated basis for each subsequent taxable year, until such time as separate returns are properly filed under section 1.1502-75(c) of the regulations. The term `two consecutive taxable years' as used in section 1.1502-5 of the regulations means any two consecutive years.

Accordingly, the affiliated group is required to file its declaration of estimated tax on a consolidated basis for the calendar year 1967.