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Court finds properties weren’t worthless or abandoned





Court finds properties weren’t worthless or abandoned. The sole shareholder of an S corporation claimed net operating loss (NOL) carrybacks in respect to real estate he said was either abandoned or rendered worthless by the 2008 housing crisis. The 11th Circuit Court of Appeals, affirming the U.S. Tax Court, upheld the IRS’s disallowance of the NOL carrybacks. The appeals court found that the taxpayer’s actions, which included sales and development activities on the properties after 2008, belied his claims of worthlessness or abandonment. (118 AFTR 2d, 2016-5521)

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