The petitioner's S corporation sustained losses which the petitioner carried forward to offset income in the carry forward years. The IRS denied the carry forward of the NOLs because the petitioner did not establish that he had waived the carryback period, failed to show that the losses had not been absorbed in an earlier year, and even failed to show that the S corporation incurred the losses. The court agreed with the IRS and also noted that the petitioner failed to show that the petitioner had sufficient basis in the S corporation shares. Jasperson v. Comr., T.C. Memo. 2015-186.