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and 1991 Federal income taxes in the amounts of $2,734 and
$6,418, respectively.
The issue for decision is whether petitioner is entitled to
carry forward 1983 and 1984 net operating losses to the tax years
at issue.
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed his
petition, petitioner resided in Arcadia, California.
Background
Petitioner operated a sole proprietorship selling yachts
during the years relevant to this case. In 1983, he incurred a
net operating loss (NOL) of $27,488. In 1984, petitioner
incurred another NOL in the amount of $11,064. Petitioner
carried the NOL’s forward, and because of additional NOL’s
incurred in 1985 and 1986, the losses were carried forward to the
years in issue, 1990 and 1991.2 Petitioner did not carry the
1983 and 1984 NOL’s back to prior years, nor did he make an
election to waive carryback to prior years. If petitioner had
carried the 1983 and 1984 NOL’s back, they would have been fully
absorbed in 1981.
2 Respondent’s determination in the notice of deficiency
includes the allowance of the carryforward of the 1985 and 1986
losses and their full absorption in 1990.
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