2018 & 2019 NOL

Technical topics regarding tax preparation.
#1
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Texas
Client has $228k NOL in 2018. 2019 tax return isn't filed until 9/25/2020 (After CARES Act is passed) at which point ~ $92k of the NOL was absorbed leaving ~ $136k of the NOL to be carried forward for 2020. There was no election to waive the carry back made on the 2019 return. From my understanding, the NOL created in 2018 needs to have been carried back to 2013, 2014, 2015, 2016, 2017 with any remaining to be used on 2019 first. In other words, the 2019 return needs to be amended to remove the initial NOL in addition to amendments to the earlier years (assuming there was tax to absorb in the earlier years).

Thank you!
 

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