Jim Gadwood Authors "Net Operating Losses and Mistakes in Closed Tax Years" in New York Law School Law Review

April 2015
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Mr. Gadwood published an article in the New York Law School Law Review titled “Net Operating Losses and Mistakes in Closed Tax Years” (59 N.Y.L. Sch. L. Rev. 263). The article discusses how under or over-reported income discovered after the applicable statute of limitations has expired impacts taxpayers’ ability to carry net operating losses to earlier and later years. The article also observes that the IRS’s rules in this area interpret a single statutory provision to mean two different things depending on the factual circumstances.