What are the implications of a federal court's finding that a Native American is entitled to an exclusionary tax exemption under the Native American Tax Exemption Act?

Because the issues before us are purely legal, our review of the district court's decision is de novo. See In re Worcester, 811 F.2d 1224, 1229-30 (9th Cir.1987). In seeking to interpret the statute at issue we are mindful that "ambiguous statutes that contain language that can reasonably be interpreted to confer a tax exemption for [Native Americans] should be construed in their favor." Kirschling v. United States, 746 F.2d 512, 515 (9th Cir.1984). ⁸

A. Carryback of 1990 Tax Year NOLs to Offset Income Assigned

in the 1987 Tax Year.