- 5 -
that petitioner’s 1989 loss had been carried back to, and that
certain levied amounts had been applied to, petitioner’s 1988
liability, the summary did not reflect that petitioner’s 1990
loss had been carried back. There was no communication between
petitioner and the Nashville revenue officer after this letter.5
At some point between January 1992 and June 1994, petitioner
moved to Tampa, Florida. The collection file relating to
petitioner’s 1988 balance due was reassigned to a revenue officer
in the IRS office at Tampa, Florida. In June 1994, petitioner
began communicating with an Appeals officer in Tampa. After
working with petitioner on his case, the revenue officer referred
petitioner’s case to the IRS Examination Division. Upon
reviewing petitioner’s 1990 return, a revenue agent concluded
that petitioner had a valid net operating loss for 1990, although
the revenue agent did make some adjustments to petitioner’s 1990
return. The parties agreed to the adjustments proposed in the
revenue agent’s report on January 26, 1996, and petitioner
subsequently filed an amended return for 1988 requesting a
carryback of the 1990 net operating loss. On March 11, 1996,
respondent allowed the carryback of the 1990 net operating loss
and posted it to petitioner’s 1988 account as of April 15, 1991,
5 The levied amounts totaled $1,011, and it appears from
the underpayment summary offered into evidence at trial that this
amount was applied toward the self-employment taxes of $5,859,
thus reducing the self-employment taxes to $4,848.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011