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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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