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          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 the           
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