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 petitioner is entitled to the following deductions claimed...
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