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MILLER v. C.I.R.

No. 95-3040.

99 F.3d 1042 (1996)

Bradley C. MILLER and Dianne M. Miller, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

November 14, 1996.

Attorney(s) appearing for the Case

Mark A. Brown, Carlton, Fields, Ward, Emmanuel, Smith & Cutler, Tampa, FL, for Petitioners-Appellants.

Gary R. Allen, Chief, Richard Farber, Thomas J. Clark, Steven W. Parks, Loiretta C. Argrett, Appellate Section Tax Division, Dept. of Justice, Washington, DC, for Respondent-Appellee.

Before BARKETT, Circuit Judge, and DYER and HILL, Senior Circuit Judges.

HILL, Senior Circuit Judge:

This appeal from the Tax Court involves the issue of whether the taxpayers' election statement under Internal Revenue Code Section 172(b)(3)(C)1 unequivocally communicated their intent to relinquish the carryback period for both a net operating loss (NOL) and an alternative minimum tax net operating loss (AMT NOL). Finding that it did not, we reverse the decision of the Tax Court.

I.

Bradley...

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