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At some point in time not clearly disclosed by the record,
but before February 1994, Moncor Bank was taken over by the
Federal Deposit Insurance Corp. (FDIC) and placed in
receivership.
On or about January 31, 1994, petitioner received four Forms
1099-G (the Forms 1099-G). Each of the Forms 1099-G was issued
for the calendar year 1993 and referenced petitioner's tax
identification number. Each of the Forms 1099-G disclosed income
from discharge of indebtedness in the identical amount of
$251,203.73 and stated that such income was being reported to the
Internal Revenue Service (IRS).
Two of the Forms 1099-G were purportedly issued by Arizona
Commerce Bank c/o the FDIC in Denver, Colorado (the original
Forms 1099-G).3 The original Forms 1099-G disclosed the employer
identification number (EIN) of the issuer of such forms as 86-
0381653. The other two Forms 1099-G were marked "correction" and
were purportedly issued by "c/o" the FDIC in Denver, Colorado
(the corrected Forms 1099-G). The corrected Forms 1099-G did not
disclose the EIN of the issuer of such forms.
One of the original Forms 1099-G was issued to petitioner
and referenced account number 2495-2495000186271AB, whereas the
other such form was issued to "Eifert's Fashions/Shoes" and
referenced account number 2495-2495000186271AA. Similarly, one
3 The record does not disclose what relationship, if any,
Arizona Commerce Bank may have had to Moncor Bank.
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