8 The following losses are in dispute: Acctg fees re: Acctg fees re: Prof. Tax audited financial employee benefits fees year statements and SEC financial Re: IRS ending regis. statements statements audit 11/30/89 $631,109 $34,450 -- 11/30/90 552,000 24,500 -- 11/30/91 337,700 24,500 $140,186.50 11/30/92 287,500 17,200 427,787.50 Petitioners reported that they had losses on their 1989, 1990, 1991, and 1992 returns, part of which petitioners carried back as specified liability losses under section 172(b)(1)(C) to the year ending November 30, 1985. Petitioners reported taxable income of more than $6,484,484 on the returns they originally filed for 1985. Petitioners' specified liability losses included payments to their public auditors and to the SEC in connection with petitioners’ compliance with the 1934 Act and ERISA and payments for legal and accounting services in connection with the IRS audits. The parties agree that the SEC and ERISA professional fees and the IRS examination expenses described above are deductible under chapter 1. Discussion The parties have stipulated the amount of petitioners’ net operating losses. The only issue for us to decide is whether petitioners may carry those losses back 10 years or 3 years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011