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Thereafter, in the same decree, petitioner was awarded "one-half
of the net operating tax loss carry forward balance for use on
unfiled and future returns."
The 1992 Federal income tax return by petitioner and Mr.
Gurr was filed on January 21, 1994, as a joint return.
Petitioner and Mr. Gurr were separated at that time. The return
was prepared at the direction of Mr. Gurr by his return preparer,
a certified public accountant. Petitioner did not sign that
return and never authorized anyone to sign the return for her.
She did not know a return had been filed for 1992. Nevertheless,
petitioner at trial stipulated that she intended to file a joint
return for 1992 and did not challenge any of the income or
expenses reported on the return.
The 1993 Federal income tax return was also filed as a joint
return on May 9, 1996, after the divorce with Mr. Gurr.
Petitioner signed that return at the offices of her divorce
attorney.
At the time petitioner signed the 1993 return, she was
accompanied to her attorney's office by her daughter. Petitioner
was not comfortable with the net operating loss deduction of
$158,841 claimed on page one of the return (which she referred to
6(...continued)
operating loss carryover worksheet that was included with the
1993 return.
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