10 2. Specified Liability Losses Section 172(f) defines a specified liability loss in pertinent part as follows: (1) In general.--The term “specified liability loss” means the sum of the following amounts to the extent taken into account in computing the net operating loss for the taxable year: * * * * * * * (B) Any amount (not described in subparagraph (A)) allowable as a deduction under this chapter with respect to a liability which arises under a Federal or State law * * * if-- (i) * * * the act (or failure to act) giving rise to such liability occurs at least 3 years before the beginning of the taxable year, * * * * * * * A liability shall not be taken into account under subparagraph (B) unless the taxpayer used an accrual method of accounting throughout the period or periods during which the acts or failures to act giving rise to such liability occurred. (2) Limitation.--The amount of the specified liability loss for any taxable year shall not exceed the amount of the net operating loss for such taxable year. The 10-year carryback for specified liability losses described in section 172(f)(1)(B) applies if: (1) The taxpayer took the specified liability loss into account in computing its net operating loss for the taxable year; (2) the expense resulting in the specified liability loss is deductible under chapter 1 of the Internal Revenue Code;Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011