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NOL |
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| If a taxpayer files an amended return to claim a deduction rather than a credit for foreign taxes paid, and the deduction creates a net operating loss (NOL) for the year, is the taxpayer subject to a three-year or a 10-year limitations period for obtaining a refund of an overpayment that is created by an NOL carryback? IRC section 382 limits the use of NOL carryforwards following an ownership change. Individuals, estates and trusts may have an NOL if deductions exceed income for the year. |
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