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supra; cf. sec. 1374(b)(2)5 (allowing NOL carryforward
"Notwithstanding section 1371(b)(1)"). Similarly, it appears
Congress intended section 1371(b)(1) to apply to carryover of
research and other business credits. See sec. 1374(b)(3)(B)
(allowing business credit carryforwards "Notwithstanding section
1371(b)(1)"). In short, Congress evinced an intention to
recognize specific exceptions, rather than a general exception to
the application of section 1371(b)(1). It does not follow, as
petitioner suggests, from the fact that the statute specifies
certain items to be excluded from the application of section
1371(b) for one purpose, namely built-in gains under section
1374, that other items are excluded from the application of
section 1371(b) for other purposes.
Thus, even if section 469 is treated as an accounting
method, we are still left with the question whether section
1371(b)(1) applies to a particular item, in this case, PAL's.
Moreover, we note that, although Congress placed section 469 in a
part of the Code entitled "Methods of Accounting", the
legislative history indicates that such treatment is not as
significant as petitioner would have us believe. The statute
itself and the legislative history treat section 469 separately
5 Sec. 1374(b) provides limited exceptions for the purpose
of calculating the tax on built-in gains, a tax imposed on the S
corporation resulting from a subchapter S election by a C
corporation which at the time of the election has unrealized
gains on its properties. See supra note 2. The instant case
does not involve the tax on built-in gains.
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