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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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