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.