Ron Lykins, Inc. v. Comm'r
United States Tax Court
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.
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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 timely petition with respect to that notice of deficiency. During the deficiency case, the IRS Office of Appeals considered P's NOL carrybacks and determined not to…
1Opinion of the Court
RON LYKINS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Ron Lykins, Inc. v. Comm'r
No. 10034-07L
United States Tax Court
133 T.C. 87; 2009 U.S. Tax Ct. LEXIS 25; 133 T.C. No. 5;
September 2, 2009, Filed
Ron Lykins, Inc. v. Comm'r, T.C. Memo 2006-35, 2006 Tax Ct. Memo LEXIS 35 (T.C., 2006)
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…
2Cases cited36 opinions
- Allen v. McCurrySupreme Court of the United States · 1980
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Cromwell v. County of SacSupreme Court of the United States · 1877
- Naftel v. CommissionerUnited States Tax Court · 1985
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