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collection based upon petitioners’ refund claim for 1985. On
June 22, 1992, Specialist Brunk accommodated petitioners and
placed a collection hold on the outstanding balance for the 1981
tax year until November 28, 1992.3 Because petitioners requested
and were granted extensions, the collection hold remained in
place until at least June 29, 1995.
1985 and 1988 Amended Tax Returns
On August 11, 1990, petitioners filed a Form 1040X, Amended
U.S. Individual Income Tax Return, for 1985 seeking a refund of
$64,408 by carrying back a $330,000 net operating loss generated
in another tax year. On August 27, 1990, respondent mailed a
notice to petitioners stating that their refund claim was
incomplete and requesting the year in which the net operating
loss allegedly was generated. In conjunction with the 1985
amended return, on October 17, 1990, petitioners filed a Form
1040X for 1988 claiming additional losses of $340,000. The
additional losses created a net operating loss for 1988 in the
amount of $336,097, of which they had carried back $330,000 to
1985. On November 8, 1990, respondent mailed petitioners a
letter stating that the Form 1040X for 1985 was being processed.
On September 5, 1991, petitioners filed a second Form 1040X for
3 Sometime after the date of assessment for the 1981 tax
year and prior to Specialist Brunk's granting Mr. Wish’s request,
petitioners’ attorney had also requested a hold on collection for
petitioners’ 1981 tax year. The IRS granted that request.
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Last modified: May 25, 2011