Sovran Bank/D.C. National v. District of Columbia

Sovran Bank/D.C. National (Sovran) appeals from an order of the trial court denying Sovran a refund for franchise taxes paid by Sovran for the years 1989 and 1990. Sovran claims that it was entitled to a deduction for certain net operating losses (NOLs) pursuant to D.C.Code § 47-1803.3(a)(14) (1997) (the NOL statute), which provides as follows:

Net Operating Losses. In computing the net income of a corporation, an unincorporated business, or financial institu tion, there shall be allowed a deduction for net operating losses, in the same manner as allowed under 172 of the Internal Revenue Code…