Donald L. Head - Page 8

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               Petitioner has failed to present any evidence on this issue.           
          Accordingly, petitioner is not entitled to the claimed dependency           
          exemption for Ms. Ratliff in 1986.                                          
          Issue 3.  Net Operating Loss Carryover                                      
               The third issue for consideration is whether petitioner is             
          entitled to a $17,769 net operating loss carryover from 1983, 1984,         
          and 1986 to 1988.  Respondent claims that the net operating loss            
          carryover was fully absorbed in previous tax years.  Petitioner             
               Section 172(a) authorizes a net operating loss deduction.              
          Simply put, a net operating loss is the excess of a taxpayer's              
          deductions over his gross income, with certain modifications.               
          These modifications, which are enumerated in section 172(d),                
          include capital gains and losses, personal exemption deductions,            
          and nonbusiness deductions.  A net operating loss in a given year           
          may be carried back for the 3 preceding years and carried forward           
          for the 15 succeeding years.  Sec. 172(b).                                  
               The taxpayer bears the burden of proving the fact and amount           
          of the  loss.  Rule  142(a); Ocean Sands Holding Corp. v.                   
          Commissioner, T.C. Memo. 1980-423, affd. without published opinion          
          701 F.2d 163 (4th Cir. 1983).  Petitioner failed to present any             
          evidence to substantiate the claimed carryover. Accordingly,                
          petitioner failed to meet his burden of proof with respect to this          
          issue.  We therefore sustain respondent's determination.                    

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