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In the October 2007 Tax Practice & Procedures item "Advantages of a C Corporation" (p. 617),Jay Starkman suggested a tax planning technique using net operating loss carrybacks and carryforwards and cautioned that there is no benefit to a personal service corporation in making a Sec. 444 election to use a fiscal year. James E. Thompson, a Rockville, Maryland, CPA, has pointed out a distinct disadvantage: Under Sec. 280H(e), a net operating loss carryback is not allowed while a Sec. 444 election is in effect.
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Title Annotation:Tax Practice & Procedures
Publication:The Tax Adviser
Article Type:Correction notice
Date:Jan 1, 2008
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