McCREE, Circuit Judge.
This appeal requires us to define the relationship between the alternative capital gains tax provisions of section 1201(b) of the Internal Revenue Code of 1954, 26 U.S.C. § 1201(b), and the net operating loss carryback and carryover provisions of section 172 of the Code, 26 U.S.C. § 172. Specifically, we must determine whether "taxable income," against which section 172 of the Internal Revenue Code requires a net operating loss carried...
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