T.C. Memo. 2002-191
UNITED STATES TAX COURT
GEORGE W. EARNSHAW, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5221-01. Filed August 5, 2002.
George W. Earnshaw, pro se.
Charles M. Berlau, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of $3,514
in petitioner’s Federal income taxes for 1998. The issue for
decision is whether petitioner must recognize discharge of
indebtedness income as a result of settlement of his Mastercard
account with MBNA America Bank (MBNA). Unless otherwise
indicated, all section references are to the Internal Revenue
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