Connecticut Limits $60 Million NOL Carryback
Recognizing that Connecticut individual state income taxes are a creature of statute, see § 12-700 et seq., the lack of statutory authority to deduct NOLs arrived at under federal tax laws, precludes the plaintiffs from deducting NOLs from CAGI rather than federal taxable income. NOLs were created under federal tax laws to deal with excess business losses used to offset positive income years arrived at under federal tax laws. Federal tax laws provide for the limitation on the use of NOLs to taxable income rather than AGI. This is more in line with the application of federal tax concepts to Connecticut tax laws. Considering all of the factors in this case, the only conclusion for the court to arrive at is that the plaintiffs are limited to applying their federal NOLs to federal taxable income rather than to CAGI, which is, in fact, federal AGI.
Constitutionally Challenged Co-defendant Does Not Create Mistrial For Tax Fraudster
I learned the basics of what goes into OID computations when I was getting a master’s degree in applied mathematics, but that probably makes it sound a little harder than it is. Just remember (1+r)^t. As a matter of fact, with excel you don’t even have to remember that anymore, but I still use it. I found though that it was pretty tough to find a staff person to work on the OID computations that a client of mine generated. Remember the population I was drawing from had at least bachelor’s degrees in accounting and had grown up using computers. It really seems that people for whom present value concepts become intuitively obvious are rather rare. This is what may account for the wackadoodle redemption theorists latching on the OID form, since they are constitutionally incapable of understanding what OID actually is and will not find too many people who are able to explain it to them. What is really sad is that the IRS systems were so porous that the technique often worked on a superficial level.
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Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.