Edward C. Tietig - Page 36




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          $8,939.  This resulted in a loss on Schedule E of $113,928.  On             
          Schedule 2, petitioner reported that $104,675 of the $122,867               
          nonpassive losses was from Farm & Grove.  After adjusting for               
          $24,600 in income reported on Form 1099-MISC, Miscellaneous                 
          Income, and $597 in interest income, petitioner reported a                  
          negative adjusted gross income of $89,26938 on page 1 of his 1992           
          Federal income tax return.                                                  
               On his 1993 income tax return, petitioner claimed a net                
          operating loss carryover deduction of $179,937.  On a supporting            
          schedule for line 22, other income, petitioner included a                   
          statement showing that the $179,937 claimed deduction was the sum           
          of an alleged $90,07139 loss in 1990 and an alleged  $89,866 loss           
          in 1992.40                                                                  
               Petitioner’s amended income tax return for 1991 removed the            
          net operating loss carryforward deduction he had claimed on his             
          original 1991 Federal income tax return.  The amended 1991 tax              
          return bore the notation that the 1990 net operating loss had               
          been carried back in full to 1988 and 1989.                                 
               B.   Discussion                                                        
               Respondent increased petitioner’s 1993 gross income by                 
          disallowing a $179,937 net operating loss carryforward                      


               38We note that $597 + $24,600 + ($113,928) = ($88,731).                
               39It is unclear how petitioner arrived at this amount.                 
               40It is unclear how petitioner arrived at this amount.                 





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