- 4 - ELECTION TO RELINQUISH NET OPERATING LOSS CARRYBACK PERIOD DIESEL PERFORMANCE, INC. EIN: 94-2194385 FORM 1120 Fiscal Year Ended June 30, 1992 Taxpayer incurred a net operating loss in its taxable year ended June 30, 1992, and is entitled to a three- year carryback period with respect to that loss under Code Section 172(b)(1) of the Internal Revenue Code. Pursuant to Code Section 172(b)(3)(C), the taxpayer hereby elects to relinquish the entire carryback period with respect to the net operating loss incurred in its taxable year ended June 30, 1992. On petitioner's Form 1120 filed for the tax year ending June 30, 1994, petitioner claimed a reduction in gross income in an amount representing the net operating loss from the June 30, 1992, period. In auditing petitioner's June 30, 1994, Form 1120, respondent disallowed the net operating loss carryover from June 30, 1992, on the grounds petitioner had not included a valid election to waive the carryback period on a return filed by the original due date. Respondent issued a notice of deficiency for the taxable year ending June 30, 1994, disallowing $55,769 of the net operating loss petitioner attempted to carry forward to the June 30, 1994, taxable year. On petitioner's original Forms 1120 for the taxable years ending June 30, 1989, and 1990, petitioner reported net taxable income of $109,646 and $191,445, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011