In 2011, Salt Lake Resorts Inc. generated a capital gain of $300,000 and no other taxable income or loss. In 2013, the corporation suffered a net operating loss of $50,000, which was carried back to 2011. Salt Lake Resorts Inc, did not make an election to carry forward only. The corporation has large tax preferences. The IRS claims that (1) no tax benefit results from the carryback, and (2) the NOL is nevertheless used up. Salt Lake Resorts Inc. believes that either a tax benefit results or it can carry forward the $50,000 net operating loss to 2014. Is the IRS right? Why?