Michael Friedman and Madeline Friedman - Page 15

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               Moreover, the abandonment of collateral otherwise deemed               
          worthless and which represents a debt's sole payment source is an           
          "identifiable event" which establishes the moment when the                  
          underlying debt is discharged.  Cozzi v. Commissioner, supra at             
          445-447; see also Brountas v. Commissioner, 74 T.C. 1062, 1074              
          (1980), supplementing 73 T.C. 491 (1979), vacated and remanded on           
          other grounds 692 F.2d 152 (1st Cir. 1982), affd. in part and               
          revd. in part on other grounds sub nom. CRC Corp. v.                        
          Commissioner, 693 F.2d 281 (3d Cir. 1982).                                  
               As a general matter, petitioners assert that respondent                
          narrowly interprets the word, "discharge" for purposes of section           
          108(a).  In particular, petitioners' arguments focus on the words           
          "title 11 case," in section 108(a)(1)(A) and (d)(2).  Petitioners           
          assert that the bankruptcy court's assumption of jurisdiction               
          over New Manchester, and the trustee's undertaking to manage New            
          Manchester's affairs in bankruptcy, occurred in a title 11 case             
          in 1992 and should, therefore, be deemed to constitute a                    
          discharge of indebtedness for purposes of section 108(d)(2).                
          Conversely, respondent argues, that, during 1992, the bankruptcy            
          court did not effectuate a plan which discharged New Manchester's           
          outstanding debts, or, in fact, grant such a discharge.  In that            
          regard, respondent points out that New Manchester possessed                 
          assets at the end of the taxable year, 1992, and that the                   







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