Items not taken into account.
Items not taken into account. For purposes of paragraph (c)(3)(i) of this section, the following items are not taken into account
(A) The net operating loss deduction allowable for the taxable year under section 172(a),
(B) Any foreign expropriation loss (as defined in section 172(h)) for the taxable year, and
(C) Any loss for the taxable year which arises from fire, storm, shipwreck, or other casualty, or from theft.