Ragnhild A. Westby - Page 17

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          The potential NOL carryforward to the years at issue, based upon            
          petitioner’s 1980-86 returns as filed, is $108,007.10                       
               There was no examination of the NOL carryforwards during the           
          audit and only a minimal examination of a portion of the NOL                
          carryforwards by the IRS Appeals Office.  In support of the                 
          alleged NOL carryforwards, petitioner testified that, because of            
          serious medical problems she experienced during 1982-86, her law            
          practice during those years operated at a loss, generating part             
          of the NOL carryforwards.  Petitioner testified that the Schedule           
          E, Supplemental Income and Loss, losses generating the remaining            
          part of the NOL carryforwards arose from the rehabilitation of a            
          rental property.  Toward the end of the trial, petitioner                   
          introduced documentation in the form of deposit slips, canceled             
          checks, and payment receipts for both her Schedule C and Schedule           
          E income and expenses during 1978-83, but she did not offer any             

               10Petitioner’s potential loss carryforward arises out of the           
          following reported results for 1980-86:                                     
                         Reported operating       Operating loss                      
               Year        income (loss)           utilization                        
               1980      ($41,399)                $7,382 carried                      
                                                  back to 1977                        
               1981           4,354          Offset by 1980 loss                      
               1982           (48,861)                 --                             
               1983           (5,051)                  --                             
               1984      14,599              Offset by 1980 loss                      
               1985           (19,643)                 --                             
               1986           (19,388)                 --                             
               Petitioner also reported operating losses in 1978 and 1979             
          which were carried back to 1976 and 1977.                                   





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