- 7 -
F.2d 376, 379 (8th Cir. 1987); Bay Sound Transp. Co. v. United
States, 410 F.2d 505, 511 (5th Cir. 1969).
Petitioners contend that they paid $26,435 in 2000 and
$29,354 in 2001 for medical and dental expenses, $3,073 in 2000
and $3,225 in 2001 for real estate taxes, $833 in 2000 and $419
in 2001 for other taxes, $99 in 2000 for home mortgage interest,
$3,515 in 2001 for cash contributions, and $1,453 in 2000 for
miscellaneous expenses, and made noncash contributions worth $500
in 2000 and $100 in 2001. Petitioners offered no evidence.
We conclude that petitioners are not entitled to more
itemized deductions than respondent allowed for 2000 and 2001.
C. Whether Petitioners May Deduct Net Operating Loss
Carryforwards and Carrybacks
Petitioners contend that they may deduct NOL carryforwards
and carrybacks. We disagree.
To carry forward or carry back NOLs, petitioners must prove
the amount of the NOL carryforward or carryback. See Jones v.
Commissioner, 25 T.C. 1100, 1104 (1956), revd. and remanded on
other grounds 259 F.2d 300 (5th Cir. 1958). Tax returns alone do
not establish that a taxpayer is entitled to NOL carryforwards or
carrybacks. Wilkinson v. Commissioner, 71 T.C. 633, 639 (1979);
Roberts v. Commissioner, supra at 837, 839. Petitioners offered
no evidence about their NOL carryforwards or carrybacks. We
conclude that petitioners are not entitled to NOL carryforward or
carryback deductions in the years in issue.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011