# Pub. L. 87-794: changes to the Internal Revenue Code 1962-10-11, 76 Stat. 889. Source: . ## Legislative history - Bill: [H.R. 11970](https://www.congress.gov/bill/87th-congress/house-bill/11970) ## § 172: Net operating loss deduction - § 172(b)(1): Pub. L. 87–794 designated existing provisions as cl. (A)(i) and struck out provisions therefrom which authorized a net operating loss for any taxable year ending after Dec. 31, 1957, to be a net operating loss carryover to each of the 5 taxable years following the taxable year of such loss, and added cls. (A)(ii), (B), and (C). - § 172(b)(2): Pub. L. 87–794 inserted reference to subsection (j), and substituted “shall be carried to the earliest of the taxable years to which (by reason of paragraph (1))” for “shall be carried to the earliest of the 8 taxable years to which (by reason of subparagraphs (A) and (B) of paragraph (1))”, and “each of the other taxable years” for “each of the other 7 taxable years”. - § 172(b)(3): Pub. L. 87–794 added par. (3). ## § 6501: Limitations on assessment and collection - § 6501(h): Pub. L. 87–794 authorized assessment of a deficiency within 18 months after the date on which the taxpayer files in accordance with section 172(b)(3) a copy of the certification issued under section 317 of the Trade Expansion Act of 1962, whichever is later. ## § 6511: Limitations on credit or refund - § 6511(d)(2)(A): Pub. L. 87–794 inserted provisions stating that, with respect to an overpayment attributable to a net operating loss carryback to any year on account of a certification under section 317 of the Trade Expansion Act of 1962, the period of limitations shall not expire before the expiration of the sixth month following the month in which such certification is issued to the taxpayer.