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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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