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On October 7, 1998, petitioner filed Forms 1040X, Amended
U.S. Individual Income Tax Return, for 1993 and 1994. On the
1993 Form 1040X, petitioner claimed a net operating loss of
$681,065 resulting from the sale of a building in 1993. On the
1994 Form 1040X, petitioner claimed a net operating loss of
$1,694,742 as a result of a loss from the liquidation of White
Pine. In July 1999, after several negotiations, respondent’s
Examination Division and petitioner reached agreement with
respect to the losses claimed for 1993 and 1994 on petitioner’s
amended returns. The net operating loss for 1993 created a net
operating loss carryback from 1993 to 1992 entitling petitioner
to a refund for that year.
Petitioner filed an amended petition on December 28, 1998,
conforming his pleadings to the stipulation of settled issues by
formally alleging, for the first time, entitlement to increased
deductions for (1) a charitable contribution, (2) capital loss
carryforwards with respect to Tamperproof and Identrol, and (3)
capital loss carryforward with respect to Barbour Hill. Notably,
in the amended petition, petitioner did not allege entitlement to
any carryback.
Subsequently, on September 22, 1999, the parties filed with
the Court a stipulation of settlement, consisting of a
5(...continued)
for 1993 and 1994.
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