No, there is no carryback for capital losses. Capital losses can offset capital gains and up to $3,000 of ordinary income. Any capital loss over this limit can be carried forward indefinitely to offset future capital gains and, again, up to $3,000 of ordinary income.
A revenue ruling is the Commissioner’s “official interpretation of the interpretation of the law” and generally is binding on revenue agents and other IRS officials. Taxpayers generally may rely on published revenue rulings in determining the tax treatment of their own transactions that arise out of similar facts and circumstances.