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for 1985 and 1986. Consistent with the principles discussed
above, it follows that petitioner is required to substantiate the
amount of the NOL that he reported in his 1987 return and then
carried back to 1985 and 1986. See O'Connor v. Commissioner,
T.C. Memo. 1992-544.
Respondent concedes that, if petitioner substantiates the
NOL reported in his 1987 return, the NOL accrued no later than
December 31, 1987. In light of our holding that petitioner must
substantiate the NOL reported in 1987, we see no reason to
consider the matter further.
In sum, we shall deny petitioner's Motion for Summary
Judgment. To reflect the foregoing,
An order will be issued
denying petitioner's Motion
for Summary Judgment.
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Last modified: May 25, 2011