Ron Lykins, Inc. v. Commissioner

133 T.C. No. 5

UNITED STATES TAX COURT RON LYKINS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10034-07L. Filed September 2, 2009. P filed a corporate tax return for 2001 reporting a net operating loss (NOL). P then requested tentative refunds for 1999 and 2000 from the NOL carryback into those years, pursuant to I.R.C. sec. 6411. The IRS allowed those refunds in December 2002. In February 2003 R issued to P a statutory notice of deficiency for 1999 and 2000 that made no adjustment related to, nor any mention of, the NOL carryback or the refunds. P filed a…