118 T.C. No. 18
UNITED STATES TAX COURT
RICHARD T. WAGNER AND MARGIE WAGNER, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7186-00L. Filed April 15, 2002.
Ps petitioned the Court under sec. 6320(c),
I.R.C., to review a notice of a Federal tax lien placed
upon their property for 1991 and 1996 Federal income
taxes. Ps contend that they are entitled to carry back
to 1991 a net operating loss that they incurred in
1994. Ps now move the Court to dismiss this case.
Held: We shall grant Ps’ motion. Estate of Ming v.
Commissioner, 62 T.C. 519 (1974), distinguished.
Keith H. Johnson, for petitioners.
William R. McCants, for respondent.
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