Clifford E. Barbour, Jr. and Dorothy D. Barbour - Page 6




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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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