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letter copies of the Discharge of Debtor, the bankruptcy schedule
on which petitioner had set forth all of her liabilities, the
Forms 1099-G, and the letters dated January 28, 1994, from the
FDIC.
On August 14, 1996, petitioner's counsel received a
communication dated August 9, 1996, from the FDIC regarding the
relationship of the Forms 1099-G to the Moncor Bank debt. The
FDIC communication, in the form of a "Corrected Paid Information
Statement", confirmed that indebtedness in the amount of
$251,203.73 was discharged in 1993 and that such indebtedness
related to Moncor Bank. The FDIC letter offered no explanation
why petitioner had received four Forms 1099-G; it offered no
explanation why petitioner had received those forms more than 7
years after the Moncor Bank debt had been discharged in
bankruptcy; and it offered no explanation why 1993 was identified
as the year in which the indebtedness was discharged.9
Attached to the FDIC communication was a "corrected" Form
1099-C (Cancellation of Debt) for the taxable year 1995 that had
been altered by hand to reference the taxable year 1993. That
9 The FDIC first became subject to the reporting
requirements relating to the cancellation of indebtedness in
1993. See sec. 6050P, as enacted by sec. 13252(a), Omnibus
Budget Reconciliation Act of 1993 (OBRA), Pub. L. 103-66, 107
Stat. 312, 531-532. Insofar as the FDIC was concerned, reporting
was only required in respect of indebtedness discharged after
Aug. 10, 1993, the date of OBRA's enactment. OBRA sec.
13252(d)(2), 107 Stat. 532. Prior to the enactment of sec.
6050P, the FDIC did not report the cancellation of indebtedness.
H. Conf. Rept. 103-213, 1993-3 C.B. 393, 549.
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