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REILLY v. COMMISSIONER

Docket No. 18616-88.

57 T.C.M. 806 (1989)

T.C. Memo. 1989-312

Robert J. and Doris M. Reilly v. Commissioner.

United States Tax Court.

Filed June 26, 1989.

Attorney(s) appearing for the Case

Jerome Blut, 550 E. Charlston Blvd., Las Vegas, Nev., for the petitioners. Paul L. Dixon, for the respondent.

Memorandum Opinion

FAY, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1975 in the amount of $20,484. The issue for decision is the determination of the amount of petitioners' proper net operating loss (NOL) and investment tax credit (ITC) carried back from 1978 to 1975. In order to make such determination, we must first determine the proper amount of NOL and ITC to be carried back from the taxable year 1977.

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