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Internal Revenue Service Memorandum

Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201208027 Release Date: 2/24/2012CC:PA:06:RLGregoryPOSTF-128317- 11 date: November 2, 2011 to: Frances F. ReganArea Counsel 1 (Manhattan) (Small Business/Self-Employed) from: Barbara M. PettoniSenior Technical Reviewer(Procedure & Administration) subject: Applicability of Mitigation Provisions to Net Operating LossesThis Chief Counsel Advice responds to your request for assistance. This advice may not be used or cited as precedent. This writing may contain privileged information. Any unauthorized disclosure of this writing may undermine our ability to protect the privileged information.

described by one of the circumstances of adjustment paragraphs in section 1312. In order for mitigation to apply, additional requirements in sections 1311(a) and (b) must

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