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On April 14, 1997, petitioner filed a Form 1040X, Amended
U.S. Individual Income Tax Return, for 1996 (amendment No. 1)
with an attached revised Form 1040 for 1996 conforming to
amendment No. 1. On line 1, column A, of amendment No. 1, the
space for reporting adjusted gross income as originally reported,
petitioner listed negative $52,690 rather than the negative
$68,713 adjusted gross income reported on the original return.
Petitioner reported a net change in adjusted gross income of a
negative $97,442 for a total adjusted gross income of negative
$150,132. The attached revised Form 1040 also shows total and
adjusted gross income of negative $150,132.
Another amended return for 1996 for petitioner was filed on
January 22, 1999, making an additional small change. The parties
agree that petitioner had a net operating loss (NOL) for 1996 of
$154,132.
When petitioner filed her Federal income tax return for
1998, she reported wages of $94,602.17, a current business loss
of $7,098.56, and a loss of $118,960.00 as "other income".
Upon examination of petitioner's return for 1998, respondent
determined that she had not relinquished the 3-year carryback
period for the loss reported on her return for 1996. Initially
unable to find evidence of her having filed a Federal tax return
for 1993, respondent determined that petitioner's loss for 1996
should be carried back to 1994 and 1995. Respondent's
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