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.
We closed year
2011 by holding our annual meeting, dinner and drawing at the little schoolhouse that was festively decorated for the Christmas season.
With a 114-year history of activities in Brazil, the company closed year
2009 with assets totaling R$ 12.
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.
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.
4) In the case of a bilateral APA, rollback or closed year
(68) considerations "did not influence" the prior TPM.
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 real advantage is that there is no such thing as a closed year
for this benefit.
The question arose because the partners claimed losses attributable to the closed year
in subsequent open years.
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.
Going forward, Standard & Poor's expects that assessments will show some improvement in subsequent releases as forecasts are turned into closed year
profits," said Mr.
Support for this position was found in the "duty of consistency," which the IRS concluded prevented a taxpayer receiving a tax benefit from its treatment of an item in a closed year
from claiming that the original treatment was incorrect and thus obtaining a tax advantage in a later year.