Taxpayer’s
                                                  Aggregate Group (cont’d) 2
                                                      an aggregate group is made as of
                  Determination of
                                                               taxable year
                  the end of taxpayer’s
                        •	  Exclude transactions between members
                                                                                                            of the
                             taxpayer’s aggregate group that were members
                                                                                                                          at
                             the time of the transaction in determining gross
                             receipts and BE%
                                                                                                                                     18