A New York City Administrative Law Judge has held that a corporation’s net operating loss deduction under the general corporation tax is limited to NOLs having the same source year as deducted for federal income tax purposes for the same tax year. Matter of Plasmanet, Inc., TAT (H) 12-17 (GC) (N.Y.C. Tax App. Trib., Admin. Law Judge Div., Sept. 29, 2015). The fact that federal NOL amounts from multiple years must also be aggregated for GCT purposes does not eliminate the application of the same source year limitation. The ALJ did abate substantial understatement of tax penalties because the taxpayer made adequate disclosure on its GCT returns.