- 21 -                                         
          salaries, tips, etc.”  The results of Mr. Gordon's activities as            
          a securities trader for 1983 through 1990 that were reported in             
          the returns for those years ranged from income of $345,714 for              
          1988 to a loss of $324,723 for 1986.  Ms. Gordon’s income from              
          her activities as a teacher for 1983 through 1990 that was                  
          reported as “Wages, salaries, tips, etc.” in the Gordons' returns           
          for those years ranged from $19,822 for 1983 to $37,056 for 1989.           
               In Schedule C of their 1986 return, the Gordons reported a             
          loss of $324,723 (1986 claimed Schedule C loss) that consisted of           
          the net loss of $319,973 that Mr. Gordon sustained from trading             
          options on the AMEX as an options market maker and expenses of              
          $4,750 that he incurred in connection with that trading activity.           
          Based upon discussions with B&S, it was Mr. Gordon's understand-            
          ing that his 1986 net trading loss of $319,973 should be treated            
          as an ordinary loss in the Gordons' 1986 return.  The Gordons               
          treated the 1986 Schedule C loss of $324,723 as an ordinary loss            
          in their 1986 return, used it to reduce $47,724 of income re-               
          ported in that return, and showed the balance of $276,999 of that           
          loss on page 1 of that return as "total income".                            
               In a statement that was attached to their 1986 return, the             
          Gordons indicated that they had incurred a net operating loss for           
          1986 in an undisclosed amount and that, pursuant to section                 
          172(b)(3)(C), they were making an election to relinquish the                
          carryback of that loss.                                                     
               The Gordons reported in Form 2119 (Sale or Exchange of                 
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