M. LANE POWERS v. COMMISSIONER

Docket Nos. 7766-81, 719-82.

52 T.C.M. 710 (1986)

T.C. Memo. 1986-494

M. Lane Powers v. Commissioner.

United States Tax Court.

Filed September 29, 1986.


Attorney(s) appearing for the Case

Robert I. White, for the petitioner. David W. Johnson, for the respondent.


Memorandum Opinion

CLAPP, Judge:

These consolidated cases are before the Court on Cross-Motions for Partial Summary Judgment pursuant to Rule 121.1 The issue raised in both motions is whether petitioner, as a matter of law, made an irrevocable election pursuant to section 172(b)(3)(C) to carry forward rather than carry back his 1978 and 1979 net operating losses. Respondent determined the following deficiencies in and additions...

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