Lufkin v. Department of Revenue

CARL N. BYERS, Judge.

Defendant disallowed a net operating loss (NOL) car-ryforward on plaintiffs 1985 individual income tax return. As a result, plaintiff incurred a minimum tax on certain preference items. Plaintiff appealed. The parties have stipulated the facts and thoroughly briefed the issues. The matter is before the court on cross-motions for summary judgment.

During the years 1981 through 1984 plaintiff was a resident of Connecticut but owned a ranch in Oregon. During those years the ranch incurred substantial losses. As of December 31, 1984, plaintiff had a NOL carryforward…