MEMORANDUM ORDER
FISH, District Judge.
Carole Jean Brashear ("Brashear") seeks a refund of income taxes paid, as well as interest and penalties assessed thereon, for the taxable year ending December 31, 1985. To establish her claim for a refund, Brashear seeks to carry back to her 1985 taxable year a net operating loss ("NOL") of $22,553 incurred in 1987. Joint Pretrial Order at 1-2. She also seeks a deduction of $23,900 as a dry hole loss from an...
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