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v. Commissioner, 90 T.C. 110, 115 (1988). Petitioner argues that
respondent must specify the year in which the NOL’s that produced
the disallowed carryover deduction arose and the reasons
respondent disallowed the NOL’s in that year. We disagree. The
notice of deficiency in this case identifies the years in which
the NOL deductions were disallowed and the amount of the
disallowed NOL deductions. See sec. 7522. This is a sufficient
explanation to apprise petitioner with regard to the NOL
deductions, and the burden of proof has not shifted to respondent
on that issue.
Petitioner has failed to present sufficient evidence to
substantiate the claimed carryover losses that it deducted in
taxable years 1991 or 1993. In addition, petitioner's expert
report does not address the value of the license in taxable years
1989 and 1990. We sustain respondent's determination.
Adjustment to Gross Sales
Respondent determined that petitioner's gross sales as shown
on its books and records are greater than its gross sales as
reported on its 1991 income tax return. Petitioner reduced gross
sales reflected on its books for 1991 in the amount of $7,095 in
reporting gross sales to correct a customer overbilling. It
introduced business records reflecting the overbilling, including
the invoices, a credit memorandum, and business journals. In
addition, Maitland explained the nature of the discrepancy in the
amount of gross sales reported and shown on petitioner's books
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