Corporate ALTMIN NOL Carryback

Technical topics regarding tax preparation.
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Hello America !

New business starting in year 1.

1st year gross revenue is 2 million with taxable income of 93,000
2nd year gross revenue is 9 million with taxable income 563,000

3rd year gross revenue is 12 million with a loss of (1,439,000)

So now I am looking at years 1 and 2 and the corporate is a Small Business Corporation exempt from AMT

Year 3 the Corporation is no longer considered a SBC because average revenue for the years 1 and 2 (2 + 9 /2= 5.5) average exceeds 5 million.

So the NOL in years 3 is generated when the corp is subject to ALT MIN.

When I do the carryback of the year 3 loss to years 1 and 2, do I have to limit the NOL carryback to 90% of the AMTI for the tax years 1 and 2? Even though the corporation is exempt from AMT in years 1 and 2?

Do you have a reference to a good article or worksheet?

Thank you for your advise

Art Lander
 

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