§3004

However, unless the optional delivery contract is - 8 - converted to a mandatory delivery contract within the 60-day optional delivery period, the mortgage may not be delivered and [petitioner] will retain the entire 2-percent commitment fee required pursuant to section 3004.” The Sellers’ & Servicers’ Guide also provides: The optional delivery date stated in the purchase contract will be within 60 days from the date [petitioner] issues the purchase contract plus the 10- business-day period in

, unless the optional delivery contract is converted to a mandatory delivery contract within the 60-day optional delivery period, the mortgage may not be delivered and [petitioner] will retain the entire 2-percent commitment fee required pursuant to section 3004.” The Sellers’ & Servicers’ Guide also provides: The optional delivery date stated in the purchase contract will be within 60 days from the date [petitioner] issues the purchase contract plus the 10-business-day period in which the [orig

owever, has materially changed between 1995 (the year in which the NOL carrybacks were generated) and today. See sec. 172(f) before and after amendment by the Omnibus Consolidated and Emergency Supplemental Appropriations Act, 1999, Pub. L. 105-277, sec. 3004(a), 112 Stat. 2681-905 (which applies to NOL's arising in taxable years ending after Oct. 21, 1998). 8 A part of the refunds for 1983 and 1984 resulted from carrying back business credits generated in 1986 and 1987. 9 The advance tax paymen