- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011