Par. 4. Section 1.1502-13 is amended by adding Example 3(e) to paragraph (c)(7)(ii) to read as follows:
* * * * *
(c) * * *
(7) * * *
(ii) * * *
Example 3.
* * *
(e) Liability in excess of basis. The facts are the same as in paragraph (a) of this Example 3, except that S and B are not members of the same consolidated group immediately before S's transfer of the land to B, and the land is encumbered with an $80 liability. Immediately after the transfer, S and B are members of the same consolidated group. Thus, the transfer is an intercompany transaction to which section 357(c) does not apply pursuant to § 1.1502-80(d).
* * * * *