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track of her investments (e.g., determine the value of her
stocks).
At least for all relevant periods since 1982, Ms. Gordon
generally held any asset that she acquired, including the assets
that she inherited from her mother during 1982 and any income
produced therefrom, exclusively in her own name, and not in joint
names with Mr. Gordon. She did so in order to protect those
assets against the risks that were associated with the volatility
of Mr. Gordon's business activities.
The Gordons' Sale of the Roslyn
Residence and the Purchase of
the Lincoln Plaza Residence
On November 21, 1986, the Gordons sold for $514,000 their
principal residence in Roslyn, New York (Roslyn residence) and
realized a gain from that sale. The Gordons used those sale
proceeds in the following manner: (1) An undisclosed amount was
used to pay certain unidentified debts and certain costs and
expenses that were associated with the sale of the Roslyn resi-
dence; (2) $100,000 was used to pay off a mortgage loan ($100,000
mortgage loan) on the Roslyn residence that the Gordons had
obtained during 1986 for Mr. Gordon to use in his business
activities; and (3) the remaining amount was divided equally
between Mr. Gordon and Ms. Gordon.
Throughout the period November 1986 until November 9, 1988,
the Gordons rented for $2,350 a month a condominium located at
One Lincoln Plaza Condominiums in New York City. Ms. Gordon was
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