Maryann Larkin v. Commissioner of IRS

Maryann and Thomas Larkin (Petitioners) appeal from the United States Tax Court’s denial of their petition seeking abatement of interest that accrued on their 2006 tax liability. Petitioners incurred a 2006 liability of $76,400 due to Petitioners’ own filings and amendments in relation to a Net Operating Loss (NOL) generated by some of their businesses in 2005; when the NOL accrued in 2005, Petitioners attempted to carry its value forward without formally electing to do so. See 26 U.S.C. § 172(b)(3). In 2008, Petitioners filed amendments carrying the NOL back to 2003, which resulted in a 2003…