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her losses forward". Because there was, she testified, no
appropriate form in her tax return preparation software package,
she attached a handwritten note to her return indicating the
carryover. The note that she attached to her return for 1996
states that she is going to carry forward her loss from 1996, she
testified. Petitioner claimed that she attached such a note not
only to her original return for 1996, but also to amendment No.
1, and to each of the tax returns for 1997 and 1998.
None of the copies of the subject tax returns stipulated by
the parties have attached to them any handwritten note of any
description. The parties did, however, stipulate without further
explanation copies of undated handwritten documents titled "Tax
Year 1996". Other documents stipulated by the parties indicate
that copies of the handwritten "carryforward" notes were provided
by petitioner to the auditor during the examination of the 1998
tax return. The "Tax Year 1996" document alleged to have been
attached to the 1996 Form 1040 contains the following statement:
"The amount of -$52,690 on line 22 of the 1040 enclosed is
business losses for 1996 (see Schedule C). These losses will be
carried forward to future years to offset future income."
The "-$52,690" mentioned in the above document is not the
amount listed on line 22 or any other line of petitioner's Form
1040 for 1996. Total income and adjusted gross income on the
1996 Form 1040 was reported on lines 22 and 31 as negative
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