§65 — Ordinary loss defined

By contrast, petitioners attempt to distinguish Lane-Wells on the ground that, in that case, “the taxpayer had two separate tax liabilities—income tax liability and personal holding tax liability—each of which required a separate return.” Because section 6501(a) uses “a definite article” with “a singular subject” (the return), petitioners reason that, “absent a clear statutory or regulatory mandate to the contrary, a taxpayer should not have to file two separate returns with respect to the same

Accordingly, the safe harbor for adequate disclosure of omitted income under section 6501(e)(1)(A)(ii) does not apply .

* * * To give full effect o the differences between the regular tax and altern tive minimum tax, the term "net operating loss carry ack" in section 6501 (h) should not be considered t e same as or the equivalent of "alternative minimum tax carryback" or "alternative capital loss carryba c As we understand it, petitioners a e arguing that, because section 6501 (h) refers only to a net op rating loss carryback, and not to a net operating loss carryba k for AMT purposes, that section does not apply

.2008-261 ("We need not decide whether the evidence is admissible,, because we find that it is insufficient to establish that petitioner was financiall y disabled within the meaning of section 6511(h), .") .-.,', order the " refund.

OPINION Our jurisdiction to determine an overpayment and order a refund is provided in section 65~_2.3 The Supreme Court has 3Sec.

Code § 65.42(b)(1) (2024). 11 [*11] in South Texas. Petitioners began to purchase and sell land, mostly through entities they partially or wholly owned (Affiliated Entities). Petitioners and Affiliated Entities have bought and sold over 20,000 acres of land since 1983, almost entirely ranch land in South Texas. At the time of trial they owned over 5,00

However, section 6015(g) provides that credits or refunds shall be allowed or made to an innocent spouse to the extent attributable to the application ofsection 6015, "notwithstanding any other law or rule oflaw (other than section 65_1.1, 6512(b), 7121, or 7122)".

65.036(5) (1999). The Oregon attorney general's audit ofFoundation, a principal focus ofwhich was Foundation's expenditures for radio advertisements, had been ongoing since at least March 1998, and Foundation's tax counsel and the Oregon attorney general's office had made efforts to settle the matter in 1999. In October 1999, Foundation's tax

65.036(5) (1999). The Oregon attorney general's audit ofFoundation, a principal focus ofwhich was Foundation's expenditures for radio advertisements, had been ongoing since at least March 1998, and Foundation's tax counsel and the Oregon attorney general's office had made efforts to settle the matter in 1999. In October 1999, Foundation's tax

grounds upon which the Tax Court finds that there is an overpayment, or (c) within the period which would be appliçable under section 6511(b)(2), (c), or (d), in respect ofany claim for refund filed within the applicable period specified in section 6511 anfl before the date ofthe mailing ofthe notice ofdeficiency-- 4 20 - petition, for purposes ofsection 65.12(b)(3)(B) its claim is deemed filed on the date ofthe notice ofdeficiency, January 22, 2010.

65.067 (2009), Washington, Wash. Rev. Code. Ann. sec. 24.12.010 to .060 (West 2005), and Wyoming, Wyo. Stat. sec. 17-8-101 to -117 (2009). In addition, Arkansas and Florida have recognized the common law corporation sole. See, e.g., City of Little Rock v. Linn, 432 S.W.2d 455 (Ark. 1968); Reid v. Barry, 112 So. 846 (Fla. 1927). 'Utah Code Ann.