Beverly Gordon - Page 24

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          sale of the Roslyn residence that should be included in their               
          income for 1986.                                                            
               In their 1988 return, the Gordons reported as ordinary                 
          income the wages of $379,071 that MKI had paid to Mr. Gordon                
          during that year and claimed a net operating loss deduction of              
          $268,318 (claimed 1988 NOL deduction) that was attributable to              
          Mr. Gordon's 1986 net trading loss that they claimed in their               
          1986 return.                                                                
               In their 1989 and 1990 returns, the Gordons did not claim              
          any net operating loss deductions.                                          
               During 1992, the IRS initiated an examination of the                   
          Gordons' 1988 return.  The IRS revenue agent examining that                 
          return examined, inter alia, the claimed 1988 NOL deduction.                
          Because that claimed deduction was attributable to Mr. Gordon's             
          1986 net trading loss, that agent reexamined that loss after                
          having notified the Gordons in writing of his intention to do so.           
          Based on that reexamination, the revenue agent concluded that Mr.           
          Gordon's 1986 net trading loss constituted a capital, and not an            
          ordinary, loss and that, consequently, that loss did not result             
          in a net operating loss for 1986, and the Gordons were not                  
          entitled to the claimed 1988 NOL deduction.                                 
          The Gordons' Separation and                                                 
          Their Separation Agreement                                                  
                                                                                     
               The Gordons separated in March 1991.  Thereafter, Mr. Gordon           
          moved out of the Lincoln Plaza residence.                                   





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