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requested additional time to verify original Forms 1120S, U.S.
Income Tax Return for an S Corporation, for Tamperproof and
Identrol for 1990 that had only been filed in September 1997 and
with respect to which petitioner was claiming capital loss
carryovers to the year in issue. Respondent also requested
additional time to verify certain recently provided documentation
offered in support of petitioner’s alleged entitlement to an
additional charitable contribution deduction and investment
interest deduction. Petitioner did not oppose a continuance,
respondent’s motion was granted, and the case was continued.
Subsequently, petitioner’s case was calendared for trial at a
trial session commencing in October 1998.
In September 1998, respondent advised the Court, by trial
memorandum, that petitioner had raised new issues, claiming
additional deductions with respect to Tamperproof, Identrol, and
for a charitable contribution, that petitioner had not pleaded in
his petition and which were therefore issues not properly before
the Court.
At calendar call, on October 5, 1998, the parties filed with
the Court a stipulation of settled issues whereby petitioner
conceded, as determined in the notice of deficiency, that the
loss from White Pine claimed in 1992 was a passive activity loss,
and that for 1992 petitioner failed to report income in the
amount of $4,958. Further, the parties stipulated several other
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