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it would take 30 days to obtain a transcript but that she was
free to submit her brief without the transcript if she so chose.
Respondent’s counsel opted to wait for the transcript before
submitting a brief.
The Court ordered the filing of seriatim briefs with
petitioner’s opening brief due 2 weeks from the date of trial and
respondent’s answering brief due 30 days from the due date of
petitioner’s opening brief. The Court also gave petitioner an
opportunity to file a reply brief within 15 days from the due
date of respondent’s answering brief.
After trial but before the due date of his brief, respondent
filed a motion to extend time within which to file brief,
requesting an additional 30 days. Petitioner did not object to
the motion, and the Court granted it. Respondent subsequently
filed an answering brief. Petitioner failed to file a reply
brief.
2. Issues Raised in the Return
A. Capital Loss Carryforwards
On her 1997 Form 1040, U.S. Individual Income Tax Return,
petitioner claimed a $3,000 capital loss deduction. On her
attached Schedule D, Capital Gains and Losses, petitioner claimed
long-term capital losses of $125,339. She also prepared a
Schedule D Worksheet and a “Schedule of Carryforward Amounts to
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