Richard Leo Warbus - Page 9

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          201, 88 Stat. 79, current version at 25 U.S.C. sec. 1481 (1994).            
          This payment satisfied the remaining original loan amount, paying           
          it in full.                                                                 
               Upon payment of petitioner's obligations, however, the BIA             
          assumed the rights of the debtors insured under the fund,                   
          including the right to cancel as uncollectible any portion of               
          petitioner's obligations.  See 25 U.S.C. sec. 1491 (1994).                  
          Petitioner therefore received his discharge of indebtedness                 
          income from the Bureau of Indian Affairs, Department of the                 
          Interior, an instrumentality of the United States.  See An Act to           
          provide for the appointment of a commissioner of Indian affairs,            
          and for other purposes, July 9, 1832, ch. 174, 4 Stat. 564                  
          (1846), R.S. sec. 462, current version at 25 U.S.C. sec. 1                  
          (1994).                                                                     
               Borrowed funds are not included in a taxpayer's income.  Nor           
          are repayments of a loan deductible from income.  When, however,            
          one's obligation to repay the funds is settled for less than the            
          amount of the loan, one ordinarily realizes income from discharge           















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