- 2 - Jack Forsberg, Gary R. Shuler, Jr., and Eric Johnson, for respondent. CHIECHI, Judge: Respondent determined the following defi- ciencies in petitioner’s Federal income tax (tax): Taxable Year Ended Aug. 31 Deficiency 1993 $330,320 1994 28,346 1995 1,694,076 1996 1,978,282 In an amendment to answer, respondent alleged increases of $460,999, $473,305, and $286,223 in the deficiencies in tax for petitioner’s taxable years ended August 31, 1994, August 31, 1995, and August 31, 1996, respectively, as a result of respon- dent’s disallowance of a net operating loss (NOL) carryback to each such taxable year that petitioner claimed from its taxable year ended August 31, 1997.1 The issue remaining for decision2 is whether the limitation 1We shall refer to petitioner’s taxable years ended Aug. 31, 1993, Aug. 31, 1994, Aug. 31, 1995, Aug. 31, 1996, and Aug. 31, 1997, as taxable years 1993, 1994, 1995, 1996, and 1997, respec- tively. 2Our resolution of the issue remaining for decision will resolve the issues that respondent raised in the amendment to answer relating to the disallowance of an NOL carryback that petitioner claimed from its taxable year 1997.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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