- 2 - parties agreed to release all claims related to their business relationship, and P agreed to pay I $25,000. When the agreement was reached, M owed I $182,295. Held: P did not realize cancellation of debt income on account of the release. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: James P. Whitmer petitioned the Court to redetermine respondent’s determination with respect to his 1987 and 1988 Federal income taxes. For 1987, respondent determined a $76,005 deficiency, a $3,800 addition to tax under section 6653(a)(1)(A), and a $19,001 addition to tax under section 6661(a). Respondent also determined that petitioner was liable for an addition to tax under section 6653(a)(1)(B). For 1988, respondent determined a $17,257 deficiency and a $4,314 addition to tax under section 6661(a). Following concessions, the only issue left for decision is whether petitioner realized cancellation of debt (COD) income in 1987, on account of a settlement of a judicial proceeding in which he was a party. We hold he did not. Unless otherwise stated, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. Dollar amounts are rounded to the nearest dollar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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