- 5 - an NOL of $605,067. In addition, the parties stipulated that they had not reached an agreement as to the application of all or part of the NOL carryback to the tax year ended January 31, 1994. On June 4, 2002, the parties filed the following stipulation with respect to petitioner’s income tax liability for the tax year ended January 31, 1994: Tax liability, computed without allowance for net operating loss carryback from the tax year ended January 31, 1995, to the tax year ended January 31, 1994 $225,753.00 Tax assessed and paid 0.00 Deficiency, without allowance for net operating loss carryback 225,753.00 Reduction in liability due to net operating loss carryback 162,180.00 Deficiency, after allowance for net operating loss carryback 63,573.00 It is further stipulated that interest will be assessed as provided by law on the deficiencies due from petitioner. It is further stipulated that, effective upon the entry of this decision by the Court, the petitioner waives the restrictions contained in I.R.C. �6213(a) prohibiting assessment and collection of the deficiencies (plus statutory interest) until the decision of the Tax Court becomes final. On June 5, 2002, the Court entered a decision that there were deficiencies in income tax due from petitioner for the tax years ended January 31, 1994, 1995, and 1996, in the amounts of $63,573, $0, and $169,474, respectively, and that there was no addition to tax under section 6651(a)(1) for the tax year endedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011