1139, 2020 NOL, AMT in carryback years

Technical topics regarding tax preparation.
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Working on 2020 Form 1139 for a calendar year C-Corp client with an estimated $500,000 NOL from 2020. In each of the calendar years 2015-2018 they had taxable income of about $200,000, so the NOL completely wipes out the income and regular tax liability for 2015 and 2016, and about half of 2017 at which point the NOL is exhausted.

https://www.irs.gov/newsroom/questions-and-answers-about-nol-carrybacks-of-c-corporations-to-taxable-years-in-which-the-alternative-minimum-tax-applies

In following the FAQ #1 in the link above, the corporation's AMTNOL carryback is zero, so there is a significant amount of AMT in 2015-2017 totaling about $70,000 over the three years. Then in 2018, while there is no more NOL to carryover, the MTC of $70,000 which arose from 2015-2017 is allowed against approximately $80,000 of regular tax liability, leaving no remaining MTC.

FAQ #4 seems to indicate that we will be able to just file one Form 1139 carrying the loss back to 2015 and then forward to 2016 and 2017, resulting in refunds for those years equal to the difference between the regular tax as originally reported less the AMT as calculated after the carryback. Then the MTC can be claimed in 2018 against the original regular tax liability from that year.

I believe that if I have this all right, then we don't have to worry about the scenario in FAQ #3 nor the referenced election under 53(e) solely because we are not left with any refundable MTC after 2018. Does this sound correct? After all is said and done the total refunds for 2015-2018 with the MTC is exactly the same as if we just treated the AMTNOL to be the same as the regular NOL.

https://www.taxprotalk.com/forums/viewtopic.php?f=8&t=18480&hilit=NOL+1139

In this discussion the final poster filed an 1139 without doing this AMT calculation, but I believe the new FAQ referenced above did not apply to forms filed prior to 6/1/2020. Also, I think there is a small-employer exception which that poster may have qualified for, but my client had gross receipts of 12-15 million each year.
 

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