Aggregation of loss disallowed where return filed late and current-year losses exceed prior year amounts. Aggregation of losses is barred where the return of tax bases is not furnished by the due date; if the amount of unabsorbed current losses (ordinary, capital, speculative, horse race and special source) for the year exceeds the corresponding amount of the immediately preceding year, the excess shall not be taken into account for any purposes of the Code in subsequent years.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Aggregation of loss disallowed where return filed late and current-year losses exceed prior year amounts.
Aggregation of losses is barred where the return of tax bases is not furnished by the due date; if the amount of unabsorbed current losses (ordinary, capital, speculative, horse race and special source) for the year exceeds the corresponding amount of the immediately preceding year, the excess shall not be taken into account for any purposes of the Code in subsequent years.
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