- 8 - return that indicated their intention to make an election under section 172(b)(3) to waive the NOL carryback period. Likewise, nothing on the 1995 return itself suggested that petitioners intended to make such an election. Accordingly, we hold that petitioners did not satisfy the requirements under section 172(b)(3) for making a valid election to waive the NOL carryback period. We therefore sustain respondent’s disallowance of the NOL carryover claimed by petitioners on their 1996 return. Reviewed and adopted as the report of the Small Tax Division. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011