- 23 - and that he was allowing the claimed deduction in that return with respect to that loss. Mr. Gordon related that information to Ms. Gordon. On May 1, 1989, the IRS issued a letter (no- change letter) to the Gordons formally notifying them that the examination of their 1986 return showed that "no change" was necessary in the tax reported in that return. On December 7, 1988, the IRS received the Gordons' 1986 amended return that included an amended Form 2119. In their 1986 amended return, the Gordons included in their income a capital gain of $29,391 from the sale of the Roslyn residence, claimed a net operating loss deduction of $35,065 that was attributable to an alleged net operating loss carryover from their taxable year 1985, and reported that the loss reported in their 1986 return was increased by $5,674 from $276,999 to $282,673. In calculat- ing the capital gain from the sale of the Roslyn residence that was reported in the Gordons' 1986 amended return, the Gordons (1) indicated in that amended return and/or the amended Form 2119 that was included as part of that return that they (a) sold the Roslyn residence for $500,000, (b) had a basis in that residence, as adjusted by the IRS on audit, of $120,500, rather than $155,500, (c) consequently realized a gain of $379,500, rather than $344,500, from the sale of that residence, and (d) replaced that residence with the Lincoln Plaza residence; and (2) took account of, inter alia, the purchase price of the Lincoln Plaza residence in arriving at the portion of the capital gain from thePage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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