Karol Z. Widemon - Page 7

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          1998" which identified a long-term capital loss carryforward to             
          1998 of $122,339.                                                           
               Petitioner also took a $3,000 capital loss deduction on her            
          1998 Form 1040.  On Schedule D, petitioner claimed short-term               
          capital losses of $20,917 and long-term capital losses of $25,053           
          for 1998.  She did not attach to the return any worksheets                  
          showing calculations of capital loss carryforwards.  Line 14 of             
          Schedule D reports long-term capital loss carryforwards and also            
          requires an entry of any carryforward amounts from the previous             
          year.  Petitioner left this entry blank.                                    
               In 1999, petitioner took a $3,000 capital loss deduction on            
          her Form 1040.  Respondent reviewed the documents petitioner                
          provided, and the parties stipulated that in 1999, petitioner had           
          short-term capital gains of $1,081 and long-term capital gains of           
          $1,527.  On her Schedule D, however, petitioner reported short-             
          term capital gains of $206 and long-term capital gains and                  
          distributions of $617.  Petitioner carried forward a short-term             
          capital loss of $17,917 from 1998, resulting in a reported short-           
          term capital loss of $17,711.  Petitioner also carried forward a            
          long-term capital loss of $25,053 from 1998 resulting in a                  
          reported long-term capital loss of $24,436.  Petitioner did not             
          carry forward to 1998 or to 1999 the $125,339 long-term capital             
          loss carryforward she claimed on her 1997 tax return.                       








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