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($27,130).
4. Petitioner claimed a net operating loss for 1994
and carried a loss back to 1992. Petitioner
concedes it was not entitled to claim a net
operating loss in 1994 or carry a loss back to
1992.
5. Respondent recomputed petitioner’s environmental
tax and environmental tax deduction. Petitioner
presented no argument regarding this
recomputation, and we deem petitioner to have
conceded this adjustment.
6. Respondent determined petitioner was liable for a
civil fraud penalty for 1992 in the amount of
$20,832 pursuant to sec. 6663. Respondent
concedes that determination.
7. Respondent determined petitioner was liable for a
penalty for 1992 pursuant to sec. 6662(a) for
substantial understatement of tax. Petitioner
presented no argument regarding the penalty. We
deem petitioner to have conceded the application
of the penalty.
B. 1993:
1. Respondent adjusted petitioner’s income for 1993
to reflect additional gross receipts of
$1,199,590.
a. Petitioner concedes this adjustment, to the
extent of $326,852.
b. Respondent concedes this adjustment, to the
extent of $30,000.
c. The remaining $842,738 at issue reflects
gross receipts that respondent determined
were income to petitioner for 1993 because
respondent determined petitioner used an
incorrect method of accounting for its 1993
taxable year and readjusted petitioner’s
income to reflect income accrued under the
accrual method of accounting. The parties
stipulated that the final decision in
Cordes Fin. Corp. v. Commissioner, supra,
would decide the proper amount of
petitioner’s gross receipts for 1993. In
accordance with the parties’ stipulations,
petitioner’s income will be increased by
$405,181 from gross receipts due to a
change in accounting method.
2. Respondent readjusted petitioner’s reported bad
debt deduction for 1993 by $650,900 to reflect
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