Continental Federal Savings & Loan Ass'n v. Oklahoma Tax Commission

BRIGHTMIRE, Judge.

A taxpayer, Continental Federal Savings and Loan Association, appeals from an order of the Oklahoma Tax Commission denying a refund of income taxes paid in 1972 and 1973. Taxpayer claims that its right to the refund resulted from its carryback of a 1975 federal net operating loss. The question presented for review involves an interpretative application of the 1971 state revenue code.

I

The facts are not in dispute. Continental is an Oklahoma corporation deriving all of its income from within this state. In its 1972 and 1973 state and federal income tax returns Continental…