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loss carrybacks,5 addressing the effect of foreign tax carrybacks
on deficiency interest.
Between 1959 and 1982, Congress amended section 6601(d) and
section 6611(f) several times in order to deal with the impact of
various carrybacks on the running of interest on underpayments
and overpayments. See Act of Nov. 10, 1978, Pub. L. 95-628, sec.
8(c)(2) and (c)(3)(A) and (B), 92 Stat. 3632; Tax Reduction and
Simplification Act of 1977, Pub. L. 95-30, sec. 202(d)(4)(C) and
(D), 91 Stat. 150 (employee credit carrybacks); Tax Reform Act of
1976, Pub. L. 94-455, sec. 2107(g)(2)(C) and (D), 90 Stat. 1904
(WIN credit carryback attributable to investment tax credit
carryback from subsequent year); Revenue Act of 1971, Pub. L. 92-
178, sec. 601(d)(3) and (4), 85 Stat. 559 (work incentive credit
carrybacks); Tax Reform Act of 1969, Pub. L. 91-172, sec.
512(e)(3)(C) and (4), 83 Stat. 641 (capital loss carrybacks); Act
of Dec. 27, 1967, Pub. L. 90-225, sec. 2(e) and (f), 81 Stat.
731, 732 (unused investment tax credit arising from NOL
carrybacks); Act of Sept. 2, 1964, Pub. L. 88-571, sec. 3(d) and
(e), 78 Stat. 858 (carrybacks of certain unused deductions of
life insurance companies); Revenue Act of 1962, Pub. L. 87-834,
sec. 2(e)(2) and (3), 76 Stat. 971, 972 (1962) (investment credit
carrybacks).
5 Sec. 6601(d)(1); see supra p. 8.
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