William D. Zack - Page 3




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               2.  Whether petitioner may carry back to 1985 and 1986 a               
          purported net operating loss (NOL) from 1988.  We hold he may               
          not.                                                                        
               Unless otherwise indicated, section references are to the              
          Internal Revenue Code applicable to the relevant years, dollar              
          amounts are rounded to the dollar, and Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  
                                  FINDINGS OF FACT                                    
               Some of the facts were stipulated, and the parties’                    
          stipulation of facts and the exhibits submitted therewith are               
          incorporated herein by this reference.  When we filed                       
          petitioner’s petition, he resided in Morgantown, West Virginia.             
          He filed his 1985 and 1986 Federal income tax returns with the              
          Commissioner on July 14, 1986, and November 13, 1987,                       
          respectively.  He filed his 1988 Federal income tax return with             
          the Commissioner on November 13, 1989, and he filed a 1988 Form             
          1040X, Amended U.S. Individual Income Tax Return, with the                  
          Commissioner on October 24, 1996.                                           
               In 1976, petitioner and Lester J. Sova (Sova) formed a tool            
          and die business named Zachova Tool & Die, Inc. (Tool & Die),               
          and, 4 years later, they formed another tool and die business               
          named Zachova Industries, Inc. (Industries).  They owned equally            
          the stock of Tool & Die and Industries, and they served as the              
          companies’ president and vice president, respectively.                      






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