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deficiency may be approved on the basis of reasons other than
those relied upon by respondent and even where respondent's
reasons are incorrect. Wilkes-Barre Carriage Co. v. Commis-
sioner, 39 T.C. 839, 845 (1963), affd. 332 F.2d 421 (2d Cir.
1964).
It is Ms. Gordon's position that she does not have the
burden of showing that there is no basis in fact or in law under
section 1256(f)(3)(B) for treating any portion of the 1986 net
trading loss as an ordinary loss. Alternatively, it is Ms.
Gordon's position that if she did have that burden, we erred in
finding in our Opinion that she failed to satisfy it. Ms.
Gordon's positions are grounded on her view that the Court
decided the innocent spouse issue "against the backdrop of its
erroneous conclusion that Mr. Gordon claimed that he held most of
his options for the purposes specified in �1256(f)(3)(B)".
Although we acknowledge here, as we did in our Opinion, that Mr.
Gordon's position was not altogether clear, we were satisfied
when we issued our Opinion (as was respondent at trial and on
brief), and we are satisfied now, that Mr. Gordon did claim that
he held most of the options that generated the 1986 net trading
loss for the purposes specified in section 1256(f)(3)(B).
Indeed, Mr. Gordon stated in his trial memorandum submitted prior
to trial and throughout his opening and answering briefs submit-
ted after trial that the 1986 net trading loss constituted an
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