§13302

115-97, § 13302(b), 131 Stat. 2054, 2122, amended section 172(b) by repealing the NOL carryback and allowing for an indefinite carryforward. See Martin v. Commissioner, T.C. Memo. 2021-35, at *19 n.10. 39 In his Simultaneous Opening Brief, respondent concedes that $237,418 of his $639,482 adjustment to Shahbaz and Anna’s claimed NOL deduction for 2012 was

115-97, § 13302(a), (b), (e), 131 Stat. 2054, 2121–23, made amendments to section 172 that have no application here. 9 [*9] The parties do not dispute that the North Carolina properties were foreclosed on by lenders in 2009. However, petitioner did not report the tax implications of the foreclosures on her 2009 return. Indeed, petitioner did not report ha

115-97, § 13302(b), 131 Stat. 2054, 2122 (2017)). 3 As the Supreme Court observed in United Dominion, 532 U.S. at 829 n.6: The difference [between the specified liability losses (SLLs) at issue here and the product liability losses (PLLs) involved in that case] does not matter. The PLL was a statutory predecessor to the SLL, and PLLs were folded into the S

115-97, § 13302(b)(1), 131 Stat. 2054, 2122 (2017). However, an NOL and the carryback and carryover periods with respect thereto are determined taking into account the law applicable for the year in which the NOL arose, without regard to the law applicable for other years to which losses are carried back or forward. See Reo Motors, Inc. v. Commissioner, 33

2054, 2121–23 (2017). In 2020 Congress again amended section 172 to provide a five-year carryback of NOLs arising in tax years beginning after December 31, 2017, and before January 1, 2021. Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136, § 2303(b), 134 Stat. 281, 353–54 (2020). Henceforth, all references

2054, 2121, effective January 1, 2018, amended section 172(b) by repealing the NOL carryback and allowing for an indefinite carryforward. These new rules do not apply here. 16 [*16] their tax return, as required by Treasury Regulation § 1.172-1(c), which means that we find that they failed to substantiate their NOL deduction. V.

13302, 131 Stat. at 2121, amended section 172(b) by repealing the NOL carryback (continued...) - 20 - [*20] carry any NOL back to each of the two tax years before the year of the loss, and then carry it forward to each of the twenty tax years after the year of the loss. See sec. 172(b)(1)(A), (2). The Martins, however, claim that their NOLs d

6601(a) ofthe Internal Revenue Code provides that the IRS will charge interest on underpayments and nonpayments oftax.

05 F.2d 667 (2d Cir. 1990) (discussing circumstances in which restitution payments maybe deductible under section 165(c)(2)), rev'g and remanding 93 T.C. 108 (1989)). °The TCJA made amendments to section 172 that have no application here. S_e_e TJCA sec. 13302(a), (b), (e), 131 Stat. at 2121-2123. - 24 - [*24] 605, 621 (2000). Tax returns for prior years may be necessary to establish an NOL carryforward, see sec. 172(b)(2) and (3), but the returns themselves cannot substantiate, without other ev