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attributable to an NOL carryback from 1992), they provided
information to any other official at the IRS so as to put
respondent on notice that petitioners had claims for refunds
attributable to carrybacks of the 1992 NOL. They did not provide
such information to Special Agent Raven, nor did they convey it
by the February 14 letter or otherwise.
C. Conclusion
Petitioners did not make informal claims for refunds
attributable to NOL carrybacks from 1992 to 1989 and 1990 before
the expiration on October 15, 1996, of the period for doing so.
IV. Conclusion
Petitioners are not entitled to NOL carrybacks in the
amounts of $31,113 and $12,810, to 1989 and 1990, respectively.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011