Stephen Bernard Schachner, Jr., and Jill Francis Schachner - Page 3

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          is not reviewable by any other court, and this opinion should not           
          be cited as authority.                                                      
               Respondent determined a deficiency in petitioners’ Federal             
          income tax for 2003 in the amount of $1,950.                                
               The sole issue for decision is whether petitioners should              
          have included $7,807 of cancellation of indebtedness income on              
          their 2003 Federal income tax return.  We hold that they should             
          have done so and therefore sustain respondent’s determination.              
                                     Background                                       
               Some of the facts have been stipulated, and they are so                
          found.  We incorporate by reference the parties’ stipulation of             
          facts and accompanying exhibits.                                            
               At the time the petition was filed, Stephen Bernard                    
          Schachner (Mr. Schachner) and Jill Frances Schachner (jointly               
          petitioners) lived in Charlotte, North Carolina.                            
               In 1994, while Mr. Schachner was taking classes at a local             
          community college, he borrowed $10,030 from University Support              
          Services to purchase an Apple computer (the Apple loan).  At Mr.            
          Schachner’s request, his mother-in-law applied for the loan on              
          his behalf, and both Mr. Schachner and his mother-in-law signed             
          the Application & Promissory Note, agreeing to be jointly and               
          severally liable for the loan.                                              
               In 1995, petitioners filed a Chapter 13 bankruptcy petition            
          with the United States Bankruptcy Court for the Western District            






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