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adjustments with respect to the charitable contribution deduction
for 1992 (in the amount of $40,000), the amount of total mortgage
interest, passive activity interest, investment interest paid by
petitioner in 1989 through 1992, the amount of long-term capital
loss with respect to Tamperproof and Identrol in 1990, and the
amount of Schedule D, Capital Gains and Losses, loss for Barbour
Hill for 1991. Because these various other adjustments which the
parties had stipulated were not properly before the Court, the
Court ordered petitioner to file an amended petition to plead
properly the issues raised informally by petitioner.
The parties stipulated that as a net result of the various
adjustments, the deficiency in income tax for 1992 was greater
than the amount determined in the notice of deficiency, and that
the deficiency for that year should be increased from $47,946 to
$56,002. The parties further stipulated:
In making the determination of the deficiency for 1992
and before entering a Decision document in this case,
the parties will account for any carryforwards or
carrybacks to which the petitioners may be entitled.
The respondent agrees that the above stipulations
produce additional deductions for the petitioners in
1993 and 1994.
At calendar call respondent also agreed to a continuance of
the case in order to allow petitioner to file amended returns to
claim any net operating loss carryback from 1993 to 1992.5
5 The issue of a net operating loss carryback could not be
considered by respondent until petitioner filed amended returns
(continued...)
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