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Held: Discharge of indebtedness income received
by P from the BIA is not excludable from income under
sec. 7873 because it was not derived by P directly or
through a qualified Indian entity from a fishing-
rights-related activity.
Daniel A. Raas, for petitioner.
Christal W. Hillstead, for respondent.
OPINION
PARR, Judge: This case was heard by Special Trial Judge
John F. Dean pursuant to section 7443A(b) and Rules 180, 181, and
182.1 The Court agrees with and adopts the opinion of the
Special Trial Judge which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
DEAN, Special Trial Judge: Respondent determined a
deficiency in petitioner's 1993 Federal income tax of $3,054 and
additions to tax of $763.50 under section 6651(a) and $127.92
under section 6654(a). Petitioner concedes that he received
unreported rental income of $6,000 and nonemployee compensation
of $3,700 subject to self-employment tax, that he failed to file
a Federal income tax return for the year 1993, and that he did
1Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended. All Rule references are to
the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011