an AMTNOL to reduce the amount of his AMTI for 2000. Similar arguments, by the same counsel, have been rejected in Merlo, ... Montgomery, ... and Spitz].] Consistent with these cases, the Court finds petitioner may not carry back his AMT capital losses to reduce his AMTI in 2000, and petitioner may not claim an AMTNOL carryback to reduce his AMTI for 2000.”); Pavlosky v. United States, 2006 WL 1867468 at *2 (Bankr.S.D.Tex.2006), aff'd, Slip Op. No. 06-CV-2061 (S.D.Tex., Oct. 5, 2006) ("The Court simply does not see any 'negative adjustment’ provision applicable to individuals that counteracts the rule in § 1211 limiting deduction of capital losses (net of capital gains) by individuals to $3,000.”); Norman v. United States, Slip. Op. No. C 05-02059, 2006 WL 2038264 at *4 (N.D.Cal.2006) (<HOLDING>); Hernandez v. United States, 450 F.Supp.2d
holding retroactive application holding that the irss application of section 1211 to taxpayers amt was reasonable holding that a judge reviewing a section 363b application must find from the evidence presented a good business reason to grant such application recognizing that application of section 507a7 should be coincidental with application of section 523a5 because of identical language in the two statutes holding that section 92434 could be unconstitutional in application