Page:United States Statutes at Large Volume 123.djvu/3015

 123STA T . 2 9 9 5PUBLIC LA W 111 – 92 —NOV . 6, 2 0 09 (2)ALTERNA T IV ETA X NET OP ERATIN G LO S S D ED UC TION .—Theam e nd men t made bysu bse c t io n (b) sha l la p ply to ta x able yea r s endin g a f ter D ecember 31, 2 0 02. (3) L OSS F RO M OPERATIONS OF LIFE INSURANCE COMPA - NIES.—The amendment made by subsection (d) shall apply to losses from operations arising in taxable years ending after December 31, 200 7 . ( 4 ) TRANSITIONAL RULE.— I n the case of any net operating loss (or, in the case of a life insurance company, any loss from operations) for a taxable year ending before the date of the enactment of this Act— (A) any election made under section 172(b)(3) or 8 10(b)(3) of the Internal R e v enue C odeof1 9 8 6w ith respect to such loss may (notwithstanding such section) be revo k ed before the due date (including extension of time) for filing the return for the taxpayer ’ s last taxable year beginning in 2009, and ( B ) any application under section 6411(a) of such Code with respect to such loss shall be treated as timely filed if filed before such due date. (f) E XCEPTION FOR TAR P RECIPIENTS.—The amendments made by this section shall not apply to— (1) any taxpayer if— (A) the F ederal G overnment ac q uired before the date of the enactment of this Act an equity interest in the taxpayer pursuant to the Emergency Economic S tabili z a- tion Act of 2008, (B) the Federal Government acquired before such date of enactment any warrant (or other right) to acquire any equity interest with respect to the taxpayer pursuant to the Emergency Economic Stabilization Act of 2008, or (C) such taxpayer receives after such date of enactment funds from the Federal Government in exchange for an interest described in subparagraph (A) or (B) pursuant to a program established under title I of division A of the Emergency Economic Stabilization Act of 2008 (unless such taxpayer is a financial institution (as defined in sec- tion 3 of such Act) and the funds are received pursuant to a program established by the Secretary of the Treasury for the stated purpose of increasing the availability of credit to small businesses using funding made available under such Act), or (2) the Federal N ational M ortgage Association and the Federal H ome Loan Mortgage Corporation, and (3) any taxpayer which at any time in 2008 or 2009 was or is a member of the same affiliated group (as defined in section 1 5 04 of the Internal Revenue Code of 1986, determined without regard to subsection (b) thereof) as a taxpayer described in paragraph (1) or (2). SEC.14 .E X C LU S IONFR O MG ROSS INCOME OF Q U A LIFIE D MILI T AR YB ASE REALIGNMENT AND CLOSURE FRINGE. (a) IN GENERAL.—Subsection (n) of section 132 of the Internal Revenue Code of 1986 is amended— (1) in subparagraph (1) by striking ‘ ‘this subsection) to offset the adverse effects on housing values as a result of 26USC13 2 . 26 USC 5 6 note.