Susan G. Kilburg - Page 7

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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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