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Respondent determined, and petitioner agrees, that
petitioner had adjusted gross income amounts of $24,420, $8,623,
and $16,347 for 1988, 1989, and 1990, respectively. Petitioner
contends that she should be allowed to carry forward her
cumulative losses from 1985, 1986, and 1987 to her 1988, 1989,
and 1990 tax years in the amounts of $39,180, $14,758, and
$6,134, respectively. Respondent contends that petitioner is not
entitled to carry forward her losses from these years because
petitioner failed to make an irrevocable election on her returns
for each of these years, as required by section 172(b)(3)(C), to
relinquish the 3-year carryback period provided in section
172(b)(1)(A).
In general, section 172 allows a deduction for an amount
equal to the aggregate of the net operating loss carryover to a
taxable year plus the net operating loss carryback to that year.
See sec. 172(a). Section 172(b), as in effect for the years at
issue, required that a net operating loss first be carried back
to each of the 3 previous taxable years and, if it was unabsorbed
by those years, that the remaining portion be carried forward to
the 15 following taxable years. See sec. 172(b)(1) and (2).
Section 172(b)(3)(C), however, provides that a taxpayer may
elect to relinquish the entire carryback period and carry forward
the loss to the taxable years following the loss year. That
section further provides:
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