Robert W. Eberle and Deborah M. Eberle - Page 3




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          attempt to distinguish Nelson, but instead contend that Nelson              
          was decided incorrectly.  This case is indistinguishable from               
          Nelson, and we need not reiterate our analysis.  Accordingly, we            
          hold that the discharge of indebtedness income does not increase            
          Mr. Eberle's stock basis.                                                   
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          






























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