Tae M. & Young J. Kim - Page 7

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          Mae stock that Ms. Kim acquired as a result of the exercise of              
          certain options granted under the Fannie Mae ESPP.  Petitioners             
          also claimed in petitioners’ amended 2002 Schedule D long-term              
          capital losses of $6,410.70, $6,808.36, and $2,730 from the                 
          respective sales of certain stock of three companies.  In peti-             
          tioners’ amended 2002 Schedule D, petitioners (1) added the three           
          new long-term capital losses claimed in that amended schedule to            
          the $3,117.40 long-term capital loss that they claimed in peti-             
          tioners’ 2002 Schedule D included as part of petitioners’ 2002              
          return and (2) claimed long-term capital losses totaling                    
          $19,066.46.  In petitioners’ amended 2002 Schedule D, petitioners           
          netted the $4,234.94 of short-term capital gains and the                    
          $19,066.46 of long-term capital losses claimed in that amended              
          schedule and claimed a net capital loss of $14,831.52.3                     









               3As discussed above, in petitioners’ 2002 return, as pre-              
          scribed by sec. 1211(b), petitioners claimed as a deduction only            
          $3,000 of the $3,117.40 net capital loss claimed in the 2002                
          Schedule D included as part of that return.  Thus, the $14,831.52           
          net capital loss claimed in petitioners’ amended 2002 Schedule D            
          did not entitle petitioners to a larger net capital loss deduc-             
          tion for 2002.  However, the increased net capital loss claimed             
          in petitioners’ amended 2002 Schedule D did affect the amount of            
          petitioners’ claimed capital loss carryover to other taxable                
          years.  See sec. 1212(b)(1).                                                





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