- 2 -
decide whether petitioner may deduct the net operating loss (NOL)
claimed on its 1993 tax return. We hold it may not. Section
references are to the Internal Revenue Code in effect for the
subject years. Rule references are to the Tax Court Rules of
Practice and Procedure. Dollar amounts are rounded to the
nearest dollar.
FINDINGS OF FACT
Some facts have been stipulated. The stipulations of fact
and the exhibits submitted therewith are incorporated herein by
this reference. Petitioner is a personal service corporation
that provides dental services. Its principal place of business
at the time of the petition was in River Falls, Wisconsin.
Petitioner's stock is owned equally by two of its full-time
employees, Stephen Schwalbach (Dr. Schwalbach) and Timothy Knotek
(Dr. Knotek). Dr. Schwalbach is a dentist who has practiced
dentistry through petitioner since he graduated from dental
school in 1972. He and a classmate formed petitioner upon
graduation, and, following the classmate's departure from the
business, Dr. Schwalbach remains the only dentist to be
continually associated with petitioner since its formation.
Dr. Knotek is a dentist who has practiced dentistry through
petitioner since he graduated from dental school in 1988.
Petitioner's operations are based in River Falls in a
two-floor, 4,800-square-foot building (the River Falls building)
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011