SILVERMAN, Circuit Judge:
This case presents a conflict between provisions of the Bankruptcy Code and the Internal Revenue Code. Under Internal Revenue Code § 172, a taxpayer's election to forego a net operating loss carryback is "irrevocable." Under Bankruptcy Code § 548, a bankruptcy trustee may avoid "any transfer" of an interest of the debtor in property when made under conditions set forth in the statute as a fraudulent transfer. In this case, a trustee...
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