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Iowa 1991. In Marshalltown the taxpayer filed a Form 1139 and a Form 1120X for 1980 based on the carryback of a net operating loss from 1985 to 1979 and a resultant carryforward of investment tax credits from 1979 to 1980. Facts Carrybacks of NOLs and FTCs Tax Return for the taxable year ------- to change its election from credits under IRC 901 to deductions under IRC 164 a 3 for foreign income taxes paid or accrued in ---------. Id. at 667. The Southern District of Iowa also adopted the...
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