Loss deduction and carry-forward under § 10d EStG: Constitutional review of income tax loss treatment

The Federal Constitutional Court refused to accept the constitutional complaint for decision, thereby upholding the lower court's rulings and leaving the taxpayer's challenge unsuccessful. The case concerned a dispute over the loss deduction and loss carry-forward under Section 10d(2), Sentence 1 of the 1999 Income Tax Act, where the taxpayer alleged that the administrative and fiscal judicial treatment of these tax attributes violated their constitutional rights. The Court issued an unbundled decision without reasoning, applying the standard admissibility and merit review criteria for constitutional complaints without granting the relief sought.