13(2) instructs revenue agents that they may redetermine the correct taxable income for a closed year
to determine either the amount of the carryforward deduction reported in the open year or the amount of an NOL deduction that is absorbed in a closed year
and supports the determination of the available NOL deduction for the open year under examination.
If a taxpayer's return is selected for audit and it includes an NOL deduction from a closed year
, can the 1RS challenge the calculation of the prior-period carryover amount and, in effect, reopen a closed return?
The former Brains pub the Duke of Clarence on Clive Road in Canton, Cardiff, was closed year
We closed year
2011 by holding our annual meeting, dinner and drawing at the little schoolhouse that was festively decorated for the Christmas season.
While there was limited investment activity that has closed year
to date, there are several properties on, or coming to, the market that are expected to close in the latter half of 2005.
This does not constitute the reopening the 1991 year, but rather the consideration of a closed year
to determine the correct amount due on an open year.
The IRS examined the taxpayer's subsequent returns after the assessment period for the initial year closed and determined that the taxpayer improperly claimed the investment credit in the closed year
If the government overpays interest on a refund for a closed year
, it may not recover the amount by offset against a refund due from that year.
Thus, unless the government actually makes a deficiency claim, recoupment is not available to remedy the closed year
1963), allowed a taxpayer to adjust its NOL carryback amount absorbed in a closed year
to claim a refund in an open one.
If an adjustment in a closed year
would have resulted in a reduction of tax and not an NOL, this mechanism for capturing missed deductions in closed tax years would not be available.
Best believes the syndicate's profile is also enhanced by its excellent track record of producing profits in each closed year
since 1984, a trend that is likely to continue.