You might have a situation, for example, in which, relying on the foreign investment entity rules and the market provisions, a taxpayer generated a capital loss in an earlier year--in 2003, 2004, 2005, or 2006--or the taxpayer generated a capital gain that was offset by a capital loss carried forward on something else, and the taxpayer is quite happy to retain that capital loss or that capital gain and doesn't want to re-file to reverse those tax effects back to 2003.
On June 7th, 2007. See this statement in context.