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Taxpayer does not have any taxable income but does have a NOL carryforward. Must a 1040 be filed to keep track of the NOL carryforward?
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Hypothetically, no. But personally, I would suggest filing one anyways.
It seems less likely that the IRS could question the NOL amount if the tax return is filed (plus it starts the statue of limitations to be audited, in case they question anything else).
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I agree with @TaxGuyBill . I always have to look at the NOL worksheets to figure out if all of it survives a year with no tax liablity. If a 2021 NOL is $100K and the taxpayer has $13K income in 2022, is there still $100K left for 2023? How about if it's a capital loss carryover, instead? Or if there are both? Even if the numbers stay the same, you'll want a completed 2022 return to rollover to 2023 if the client plans on coming back next year.