Dudley B. and La Donna K. Merkel - Page 2

               Gregory W. MacNabb, for petitioners.                                   
               Ann M. Welhaf, for respondent.                                         

               HALPERN, Judge:  In these consolidated cases, respondent               
          determined deficiencies in the Federal income tax of petitioners            
          Dudley and La Donna Merkel and David and Nancy Hepburn for their            
          1991 taxable (calendar) years in the amounts of $115,420 and                
          $116,347, respectively.  Both cases involve similar circumstances           
          and require us to determine whether petitioners in the two cases            
          (the Merkels and the Hepburns, respectively) may exclude under              
          section 108(a)(1)(B) certain income from the discharge of                   
          indebtedness.  Unless otherwise noted, all section references are           
          to the Internal Revenue Code in effect for the year in issue, and           
          all Rule references are to the Tax Court Rules of Practice and              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, with accompanying exhibits, is                    
          incorporated herein by this reference.                                      
               At the time the petitions were filed, the Merkels and the              
          Hepburns resided in Scottsdale and Paradise Valley, Arizona,                
          Discharge of Indebtedness Income                                            
               During 1991, the Merkels and the Hepburns were all partners            
          in a partnership (the partnership) that, on September 1, 1991,              

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