I see no such restriction for being an Active Participant. If the CPA says that, ask that CPA for a citation.
<a rel="nofollow" target="_blank" href="
https://www.irs.gov/publications/p925#en_US_2016_publink1000104573">https://www.irs.gov/publications...>
<a rel="nofollow" target="_blank" href="
https://www.irs.gov/instructions/i8582#idm140044366636368">https://www.irs.gov/instructions/i8582#id...>
<a rel="nofollow" target="_blank" href="
https://apps.irs.gov/app/vita/content/12/12_05_005.jsp">https://apps.irs.gov/app/vita/content/12/12_...>
That CPA is absolutely wrong about amending 2012. As long as 2014 (the year of the NOL) is still an 'open' year to be amended, then the you can still amend 2012 to use the NOL. That is specifically stated in the Tax Code Section 6511(d)(2).
<a rel="nofollow" target="_blank" href="
https://www.law.cornell.edu/uscode/text/26/6511#d_2">https://www.law.cornell.edu/uscode/text/26/6511...>
