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  5. 981 F.2d 277 (1992)
 

MATTER OF LUSTER

Nos. 92-1946, 92-1973.

981 F.2d 277 (1992)

In the Matter of Melvin R. LUSTER, Debtor. In the Matter of Harold E. FRIEDMAN, Debtor. Appeal of Dennis E. QUAID, Trustee. (Two Cases)

United States Court of Appeals, Seventh Circuit.

Decided November 30, 1992.

Attorney(s) appearing for the Case

Michael J. Keaton (argued), Dennis E. Quaid, Maynard B. Russell, Fagel & Haber, Chicago, IL, for Dennis E. Quaid in No. 92-1973.

Gary R. Allen, Gary D. Gray, Edward T. Perelmuter (argued), Dept. of Justice, Tax Div., Appellate Section, Washington, DC, for U.S.

James L. Nachman, Winston & Strawn, Chicago, IL, for Harold E. Friedman in No. 92-1973.

Michael J. Keaton (argued), Dennis E. Quaid, Fagel & Haber, Chicago, IL, for Dennis E. Quaid in No. 92-1946.

James L. Nachman, Winston & Strawn, Chicago, IL, for Melvin R. Luster in No. 92-1946.

Before COFFEY and EASTERBROOK, Circuit Judges, and ENGEL, Senior Circuit Judge.

EASTERBROOK, Circuit Judge.

This case of first and last impression presents the question whether net operating loss carryforwards are "property" of the debtor's estate under the Bankruptcy Act of 1898, a statute repealed 14 years ago. Section 346(i)(1) of the Bankruptcy Code of 1978, 11 U.S.C. § 346(i)(1), provides that the estate succeeds to all tax attributes of the debtor. See also 26 U.S.C. § 1398(g). Nothing similar to § 346(i)(1) appeared in the...

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