"hereinbefore quoted, seeme to that the Congress intended an paid upon the sale or isasing to an affiliate, cannot see Sections how, except indicate clearly excise tax to be of a taxable article 600 by e and 601 sale, (a), the We ownership these bus bodies was transferred from parent subsidiery,. Seach transactien was at a profit the corporation, bach transfer was absolute, passed and the charge corporation's books arainst was the such as system would obtein hetwoen persons of these dealing kevenue Leaves no as to the existence tion between Section 840 (¢) doubt the corporation at and "On the one hand, in dealing Congress has said in seetion 601 Acts Chat the excise considering shall be arm's supra) affilia. with excise taxes, (a) of these Pevenue tax which the court is now imposed upon intercompany in of the Revenue act of intercompany transactions snall. be computing consolidated net indome the an system, bus bodies; and on the income taxes, Congress 240 lLeneth, (cuoted of transactions in in dealing with seetion the ordinarily Acts the in of to to title other hand, has said 1926 that eliminated of in affiliated corporations which elect to file consolidated returns for ineome tax purposes, In other worces, the statutory treatment of intercompany transactions seems to be exectly opposite in the determination of the excise tax of affiliated corvorations from that used in computing the consolicated income tax of affili- ante RNR HAS S ated corporations, It will be noted that in the ase of income taxes the taxpayer is given an eleetion; in the cass of excise taxes there is no choice if the texpayer permits himself to come within the act, * £% is eeetion 601 (a) true that expressly in makes or leases between affiliated 619 of Revenue Act the reference to the 1962 affiliations, It however, sales between that the law Act is not would of 1924, aprlicable eorporations, of Ciear, Revenue so seem while to Section definite to be in its culte its terms are broad enough affiliates, for, as we hereinbefore have sales to include said,