T.C. Memo. 2003-212
UNITED STATES TAX COURT
DIANE S. BLODGETT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5480-00. Filed July 16, 2003.
Diane S. Blodgett, pro se.
Melissa J. Hedtke, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: Respondent determined a
deficiency of $7,704 in petitioner’s Federal income tax for the
year 1998.
The issues for decision are: (1) Whether petitioner is
entitled to all or part of a $38,046,524 loss deduction that was
claimed on her 1998 Federal income tax return as a net operating
loss carryover from 1992, and (2) in the alternative, whether
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