Transport Labor Contract/Leasing, Inc. & Subsidiaries - Page 2

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               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.                              





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