Bolten v. Commissioner
United States Tax Court
Petitioners had a $ 781,927 net operating loss (NOL) in 1976. Pursuant to section 172 of the Internal Revenue Code, they carried it back as required and then carried it forward to the years 1977, 1978, and 1979. The amount of the 1976 NOL remaining after the deductions thus taken through 1979 was sufficient to support the NOL deduction of $ 460,382 which they took for 1980 and the final NOL deduction of $ 8,599 which they took for 1981. In 1988, when the period of…
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Petitioners had a $ 781,927 net operating loss (NOL) in 1976. Pursuant to section 172 of the Internal Revenue Code, they carried it back as required and then carried it forward to the years 1977, 1978, and 1979. The amount of the 1976 NOL remaining after the deductions thus taken through 1979 was sufficient to support the NOL deduction of $ 460,382 which they took for 1980 and the final NOL deduction of $ 8,599 which they took for 1981. In 1988, when the period of limitations for assessment of deficiencies as extended for 1980 had already expired, they entered into a closing agreement under…
1Opinion of the Court
John Bolten, Jr., and Ines Bolten, Petitioners v. Commissioner of Internal Revenue, Respondent
Bolten v. Commissioner
Docket No. 24007-88
United States Tax Court
95 T.C. 397; 1990 U.S. Tax Ct. LEXIS 98; 95 T.C. No. 29;
October 4, 1990, Filed
Decision will be entered for the respondent.
Petitioners had a $ 781,927 net operating loss (NOL) in 1976. Pursuant to section 172 of the Internal Revenue Code, they carried it back as required and then carried it forward to the years 1977, 1978, and 1979. The amount of the 1976 NOL remaining after the deductions thus taken through 1979 was sufficient to support…
2Cases cited20 opinions
- Sheila M. Jackson v. Paul A. KellyCourt of Appeals for the Tenth Circuit · 1977
- United States v. Harold Lawrence BlasiusCourt of Appeals for the Second Circuit · 1968
- United States v. Dubuque Packing Company, a Corporation, Dubuque Packing Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1956
- United States v. Foster Lumber Co.Supreme Court of the United States · 1976
- Yagoda v. CommissionerUnited States Tax Court · 1962
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