I agree, 48E credits are listed in section 6417(b), which makes them eligible to be carried back 3 years. It looks to me like you would have to report them on line 5 of Form 3800. According to the 2022 instructions for Form 3800, Line 5 is to be used only when amending to carryback credits from 2023. You have to attach a statement with information about the credit anyway, so that would include the explanation of why the credit appears on line 5.
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