T.C. Memo. 2003-244
UNITED STATES TAX COURT
ALLAN & JUDY N. GREEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7158-02. Filed August 14, 2003.
Chester A. Swart, for petitioners.
Vicken Abajian and Guy Glaser, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioners petitioned the Court to
redetermine deficiencies of $31,962 and $6,647 in their 1998 and
1999 Federal income taxes, respectively. Following concessions,
we decide whether petitioners may deduct for those years net
operating losses (NOLs) which purportedly arose in earlier years.
We hold they may not. Unless otherwise stated, section
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