I have Net Operating Losses in 2018 and 2019. Prior to the CARES act, I was unable to carry back my 2018 loss, so it was carried forward to 2019 and is reflected in my return. I attempted to file a Form 1045, Application for Tentative Refund, to carry back my NOL from 2019 (that included 2018) back to the 2017 tax year where I had positive AGI. The IRS has sent a letter back revising my Form 1045 to reduce the NOL to only reflect the 2019 loss. And normally that would make sense, but it got carried forward because the tax law changed in 2019 (disallowing carrybacks prior to the CARES act) .
Do you have a suggestion as to how I should handle this? Maybe refile the 1045 to request a refund of 2017, using only the 2019 loss then file a 1040X for 2017 to carryback only the 2018 loss? Should i do that in a certain order?
Would it be better to just file the 1040X for 2017? But if so, could I carryback both years' NOL (2018 and 2019) in one amended return? Or would I be required to first file the amended 2017 carrying back the 2018 loss first, let that get processed, then amend 2017 again to carryback 2019?
Thanks for reading!
