Authority to Postpone Certain Tax-Related Deadlines by Reason of Presidentially Declared Disasters

ID: CCA_2009100908045424 Number: 200947038
Release Date: 11/20/2009
Office: ---
UILC: 6511.00-00, 7508A.00-00
From: ---
Sent: Friday, October 09, 2009 8:05:00 AM
To: ---
Cco: ---
Subject: FW:---income tax return
Your analysis is correct as I have been advised by ---... If the time to amend the --- return has expired, then under 6511(d)(2) the taxpayer can amend ------, ---, and --- returns to claim carrybacks is with respect to losses claimed on the --- that were not available to the taxpayer at the time of filing, i.e., the losses were greater than income.
So, if time to amend the --- return has passed, the taxpayer cannot claim any additional losses that were not reported on the --- return.