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cost of the sales or services. Sec. 6501(e)(1)(A)(i); sec.
301.6501(e)-1(a)(1)(ii), Proced. & Admin. Regs. An item is not
considered omitted from the return if its nature and amount are
sufficiently disclosed in the return or any schedule or statement
attached to the return. Sec. 301.6501(e)-1(a)(1)(ii), Proced. &
Admin. Regs.
We further note that under section 6501(h), a deficiency
attributable to an NOL carryback may be assessed at any time
before the expiration of the period within which a deficiency for
the taxable year of the NOL which results in the carryback may be
assessed.
Section 6501(e) is of no assistance to respondent for the
period ending March 31, 1992, since the notice of deficiency was
mailed more than 6 years after the filing of the return.
Further, since the underpayment determined with respect to Regal
for the tax year ending March 31, 1990, is attributable to the
disallowance of the NOL carryback from the tax year ending March
31, 1992 (the year in which Regal claimed the loss arose), the
period during which the underpayment may be assessed has expired
under section 6501(h). See Calumet Indus., Inc. v. Commissioner,
95 T.C. 257, 274 (1990).
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