26 C.F.R. § 301.6501(i)-1 Foreign tax carrybacks; taxable years beginning after December 31, 1957.
Title 26 - Internal Revenue
With respect to taxable years beginning after December 31, 1957, a deficiency attributable to the application to the taxpayer of a carryback under section 904(d) (relating to carryback and carryover of excess foreign taxes), may be assessed at any time before the expiration of 1 year after the expiration of the period within which a deficiency may be assessed for the taxable year of the excess taxes described in section 904(d) which result in such carryback.
Title 26: Internal Revenue
PART 301—PROCEDURE AND ADMINISTRATION
Limitations
Limitations on Assessment and Collection
§ 301.6501(i)-1 Foreign tax carrybacks; taxable years beginning after December 31, 1957.