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summary judgment, we conclude that genuine issues of material
fact exist with respect to the computation of the amount of NOLs
available for petitioner’s 1995, 1996, and 1997 tax years. See
Dahlstrom v. Commissioner, 85 T.C. at 821. Accordingly, summary
judgment is inappropriate with respect to the remaining questions
presented in petitioner’s summary judgment motion.
An appropriate order
will be issued.
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Last modified: May 25, 2011