- 24 - sale of the Roslyn residence that should be included in their income for 1986. In their 1988 return, the Gordons reported as ordinary income the wages of $379,071 that MKI had paid to Mr. Gordon during that year and claimed a net operating loss deduction of $268,318 (claimed 1988 NOL deduction) that was attributable to Mr. Gordon's 1986 net trading loss that they claimed in their 1986 return. In their 1989 and 1990 returns, the Gordons did not claim any net operating loss deductions. During 1992, the IRS initiated an examination of the Gordons' 1988 return. The IRS revenue agent examining that return examined, inter alia, the claimed 1988 NOL deduction. Because that claimed deduction was attributable to Mr. Gordon's 1986 net trading loss, that agent reexamined that loss after having notified the Gordons in writing of his intention to do so. Based on that reexamination, the revenue agent concluded that Mr. Gordon's 1986 net trading loss constituted a capital, and not an ordinary, loss and that, consequently, that loss did not result in a net operating loss for 1986, and the Gordons were not entitled to the claimed 1988 NOL deduction. The Gordons' Separation and Their Separation Agreement The Gordons separated in March 1991. Thereafter, Mr. Gordon moved out of the Lincoln Plaza residence.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011