In 2010, Salt Lake Resorts Inc. generated a capital gain of $300,000 and no othe
ID: 2378551 • Letter: I
Question
In 2010, Salt Lake Resorts Inc. generated a capital gain of $300,000 and no other taxable income or loss. In 2012, the corporation suffered a net operating loss of $50,000, which was carried back to 2010. Salt Lake Resorts Inc. did not make an election to carryforward only. The corporation has a large tax preference. The IRS claims that (1) no tax benefit results from the carryback, and (2) the NOL is nevertheless used up. Slat Lake Resorts Inc. believes that either a tax benefit results or it can carryforward the $50,000 net operating loss to 2013. Is the IRS right? Why? In 2010, Salt Lake Resorts Inc. generated a capital gain of $300,000 and no other taxable income or loss. In 2012, the corporation suffered a net operating loss of $50,000, which was carried back to 2010. Salt Lake Resorts Inc. did not make an election to carryforward only. The corporation has a large tax preference. The IRS claims that (1) no tax benefit results from the carryback, and (2) the NOL is nevertheless used up. Slat Lake Resorts Inc. believes that either a tax benefit results or it can carryforward the $50,000 net operating loss to 2013. Is the IRS right? Why?Explanation / Answer
I personally believe that part of the reason taxpayers comply is because at some level they believe in a
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