SCHOOL STREET ASSOCIATES LIMITED PARTNERSHIP, et al. (97-TX-1442) and Sovran Bank/D.C. National (97-TX-2001), Appellants,
v.
DISTRICT OF COLUMBIA, Appellee.
District of Columbia Court of Appeals.https://leagle.com/images/logo.png
Argued En Banc May 9, 2000.
Decided January 4, 2001.
Attorney(s) appearing for the Case
Ralph A. Taylor, Jr., Washington, DC, for appellants School Street Associates Limited Partnership, et al.
Herman B. Rosenthal, with whom Richard J. Magid, Baltimore, MD, was on the brief, for appellant Sovran Bank/D.C. National.
Lutz Alexander Prager, Assistant Deputy Corporation Counsel, with whom Robert R. Rigsby, Corporation Counsel, and Charles L. Reischel, Deputy Corporation Counsel Appellate Division, were on the brief, for appellee.
Before WAGNER, Chief Judge, TERRY, STEADMAN, SCHWELB, FARRELL, REID, GLICKMAN and WASHINGTON, Associate Judges.
District of Columbia Court of Appeals.
On Rehearing En Banc
STEADMAN, Associate Judge:
Before us for en banc review are two tax appeals.1 Both require us to interpret the provision of the District of Columbia income and franchise tax statute permitting the deduction of a net operating loss ("NOL"). See D.C.Code § 47-1803.3(a)(14) (1997). That code section in general allows a deduction for a net operating loss incurred in one year against the net income...
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