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the Code. See Automobile Club of Mich. v. Commissioner, 353 U.S.
180, 183 (1957).
Nor has Mr. Gordon established that he relied to his detri-
ment on the IRS revenue agent's oral statement to him in October
1988 and the IRS' issuance of the no-change letter in May 1989 by
arranging his business affairs so that any income that he re-
ceived during 1988 and subsequent years would constitute ordinary
income that could be offset by a net operating loss deduction
attributable to his 1986 net trading loss. In this connection,
we find it significant that (1) although Mr. Gordon's employment
with MKI from which he received ordinary income during 1988
commenced sometime in January 1988, it was not until October 1988
that the IRS revenue agent told him that his 1986 net trading
loss was properly reported as an ordinary loss in the Gordons'
1986 return, and it was not until May 1989 that the IRS issued
the no-change letter to the Gordons; and (2) the Gordons did not
claim any net operating loss deductions in their 1989 and 1990
returns.
We also reject Mr. Gordon's claim that he relied to his det-
riment on the IRS revenue agent's oral statement to him in
October 1988 and the IRS' issuance of the no-change letter in May
1989 when he and Ms. Gordon did not use his 1986 net trading loss
to offset the long-term capital gain that they realized from the
sale of their Roslyn residence. The Gordons realized a gain from
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