Intermet Corporation & Subsidiaries - Page 5

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          paid the Michigan Single Business Tax deficiencies and the                  
          related interest.  The aforementioned interest on a Federal                 
          income tax deficiency arose out of an audit by the Internal                 
          Revenue Service (the Service) of the group's consolidated Federal           
          income tax returns for 1987 and the resulting adjustment to                 
          Lynchburg's separate taxable income for that year.  During 1992,            
          Lynchburg and the Service resolved their differences, and                   
          Lynchburg paid interest on its agreed upon 1987 Federal income              
          tax deficiency.  During 1992, Lynchburg properly deducted the               
          additional State taxes and interest it paid during that year.               
                                       OPINION                                        
               Section 172(a) allows a "net operating loss deduction" for             
          the aggregate of net operating loss carrybacks and carryovers to            
          the taxable year.  The term "net operating loss" (NOL) is defined           
          in section 172(c) to mean the excess of deductions allowed by               
          chapter 1 over gross income.  Section 172(b) provides the                   
          carryback and carryover periods for NOL's.  Section 172(b)(1)(A)            
          generally provides that the carryback period for an NOL is 3                
          years and that the carryover period is 15 years.1  Section                  
          172(b)(1)(C) provides a special rule that extends the carryback             
          period from 3 years to 10 years for specified liability losses.             


          1    Effective for taxable years beginning after Aug. 5, 1997,              
          the carryback period for an NOL is 2 years and the carryforward             
          period is 20 years.  Taxpayer Relief Act of 1997, Pub. L. 105-34,           
          sec. 1082(a), 111 Stat. 950.                                                




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