Beverly Gordon - Page 20

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          with information relating to the income that she received during            
          1983 through 1990 (e.g., Forms W-2 and 1099) and the expenses               
          that she paid during those years (e.g., canceled checks for                 
          charitable contributions).  Ms. Gordon relied on B&S and Mr.                
          Gordon for the preparation of the 1983 through 1989 returns.                
          Although Ms. Gordon had the opportunity to review those returns,            
          she did not.  Except for discussions with Mr. Gordon about                  
          certain important items reported in the Gordons' 1986 through               
          1989 returns, such as the gain from the sale of the Roslyn                  
          residence, Ms. Gordon did not discuss those returns with Mr.                
          Gordon or B&S.  Because she was not available at the time the               
          1986, 1987, and 1989 returns and the 1986 amended return were               
          filed, Ms. Gordon did not sign them; instead, Mr. Gordon signed             
          Ms. Gordon's name to those returns.                                         
               The Gordons’ 1983 through 1990 returns listed the respective           
          occupations of Mr. Gordon and Ms. Gordon as securities trader and           
          teacher.  The Gordons reported the results of Mr. Gordon’s                  
          activities as a securities trader in Schedules C of their returns           
          for 1983 through 1986, 1989, and 1990, regardless whether those             
          results related to his activities as a securities trader for his            
          own account or to his activities as a securities trader for the             
          accounts of the firms that employed and paid him W-2 wages.  In             
          their 1987 and 1988 returns, the Gordons reported the results of            
          Mr. Gordon's activities as a securities trader for the accounts             
          of the firms that employed and paid him W-2 wages as “Wages,                




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