摘要：In 1974 a conflict development among circuit courts over the application of the net operating loss carryback provisions of the Internal Revenue Code to years in which a corporate taxpayer enjoyed the benefit of the "alternative" method for the computation of the capital gains tax. In November 1976, the United States Supreme Court resolved the conflict in favor of the Internal Revenue Service in United States v. Foster Lumber Co. This Case Comment will analyze Foster Lumber, as well as some of the earlier conflicting decisions, in an effort to determine if the Supreme Court has effectively resolved the problem
关键词：loss carryback; capital gains tax; section 172(b)(2); Section 1201
