- 36 -
$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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