- 17 - 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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