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of the corrected 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.
On or about January 31, 1994, petitioner also received two
letters dated January 28, 1994, from the FDIC in Dallas, Texas.
One letter was addressed to petitioner and the other letter was
addressed to "Eifert's Fashions & Shoes". Each letter referenced
account number 2495000186271 and the FDIC office in Denver,
Colorado. Both letters stated as follows:
You will, or have already received Internal
Revenue Service form 1099G which reports to IRS the
full or partial discharge of your indebtedness with
respect to the debt obligation noted above. The filing
of this report with the IRS is required by section
6050P of the Internal Revenue Code of 1986. The
reporting requirement applies to all debts discharged
in full or in part, on or after the effective date of
August 10, 1993. The amount discharged may or may not
be taxable income to you, depending upon your own
circumstances. You should consult with your tax
advisor to determine whether you must report this
amount as taxable income.
In 1993, a Form 1099-G was used to report certain government
payments. In particular, box 5 of such form was used to report
discharge of indebtedness by a Federal government agency, such as
the FDIC. See sec. 6050P(c)(1)(B). The "Instructions for
Recipient" for box 5 provided in pertinent part as follows:
Box 5.--Shows your indebtedness to a Federal government
agency that was discharged this year as no longer
collectible. This debt generally becomes taxable
income to you at the time the debt is discharged.
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