Carolyn S. Eifert, A/K/A Sue Armstrong - Page 6

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               There are exceptions to this rule--for example, if you                 
               are insolvent or have declared bankruptcy.                             
          Upon receipt of the Forms 1099-G, petitioner contacted her                  
          bankruptcy attorney, who advised her to disregard the Forms 1099-           
          G because petitioner had previously been granted a discharge in             
          bankruptcy in September 1986.  Petitioner accepted her bankruptcy           
          attorney's advice and did not, at that time, pursue the matter              
          any further.                                                                
               Petitioner did not file a Federal income tax return for the            
          taxable year 1993 because her income for that year did not exceed           
          the filing threshold.  See sec. 6012(a)(1).                                 
               Information returns (i.e., Forms 1099-G) reporting the                 
          receipt of discharge-of-indebtedness income by petitioner for the           
          taxable year 1993 were filed with respondent (the information               
          returns).  Data from the information returns, as compiled by                
          respondent, revealed the following:                                         

          Payor              Payor's EIN      Payee            Amount                 
          (1) Stockmen's Bk &                     Eifert's                            
          Tr Co. c/o FDIC1    83-0199850       Fashions/Shoes  $251,203               
          (2) Stockmen's Bk &                     Eifert's                            
          Tr Co. c/o FDIC    83-0199850       Fashions/Shoes   251,203                
          Eifert's                                                                    
          (3) FDIC               75-2193552       Fashions/Shoes   251,203            
          (4) FDIC               75-2193552       Petitioner       251,203            
               1 The record does not disclose what relationship, if                   
               any, Stockmen's Bank and Trust Co. may have had to                     
               Moncor Bank.                                                           






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