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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 ended
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