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KAHLE v. COMMISSIONER

Docket No. 19713-94.

73 T.C.M. 2080 (1997)

T.C. Memo. 1997-91

Douglas E. Kahle and Barbara W. Kahle v. Commissioner.

United States Tax Court.

Filed February 20, 1997.

Attorney(s) appearing for the Case

Douglas E. Kahle, for the petitioners. Veena Luthra, for the respondent.

MEMORANDUM OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1991 in the amount of $36,783.00, as well as an addition to tax under section 6651(a)(1)1 in the amount of $8,819.75 and an accuracy-related penalty under section 6662(d) in the amount of $7,359.60. The deficiency results from the disallowance of the carryover of a net operating loss (NOL) of petitioner...

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