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PERCENTAGE LIMITATIONS(b) Carryback RulesThe amount of the excess contribution for a contribution year is not increasedbecause a net operating loss carryback is available as a deduction in the contributionyear. In addition, in determining the amount of the net operating loss forany year subsequent to the contribution year, which is a carryback or carryoverto tax years succeeding the contribution year, the amount of any charitable contributionsmust be limited to the amount of the contributions that did not exceed10 percent of the donor’s taxable income for the contribution year. 137The amount of the charitable contribution from a preceding tax year that isdeductible in a current tax year (the deduction year) cannot be reduced because anet operating loss carryback is available as a deduction in the deduction year. Inaddition, in determining the amount of the net operating loss for any tax yearsubsequent to the deduction year, which is a carryback or carryover to tax yearssucceeding the deduction year, the amount of contributions made in the deductionyear must be limited to the amount of these contributions, actually made inthat year, 138 that did not exceed 10 percent of the donor’s taxable income for thededuction year. 139(c) Year Contribution Is MadeContributions made by a corporation in a contribution year include contributionsthat are considered as paid during the contribution year. 140137Reg. § 1.170A-11(c)(3).138IRC § 170(d)(2).139Reg. § 1.170A-11(c)(4).140Reg. § 1.170A-11(c)(5). 222