Ingo H. Jensen - Page 2

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          to section 7430 and Rules 230, 231, and 232,1 filed April 14,               
               Neither party requested a hearing, and the Court concludes             
          that a hearing is not necessary for the proper disposition of               
          this motion.  Although some facts appear in dispute, those facts            
          are essentially irrelevant to our resolution of this matter.                
                                  FINDINGS OF FACT                                    
               At the time the petition was filed petitioner resided in               
          Macedonia, Ohio.                                                            
               Guild Mortgage Co. (Guild) issued petitioner a Form 1099-A,            
          Acquisition or Abandonment of Secured Property, and a Form 1099-            
          C, Cancellation of Debt, for petitioner’s 1996 taxable year.  The           
          Form 1099-C indicated cancellation of debt income of $36,865.               
          Petitioner did not include this amount in income on his 1996                
          Federal income tax return.                                                  
               Respondent mailed a CP2000 letter (commonly known as a 30-             
          day letter) to petitioner on January 13, 1998.  The letter                  
          proposed to increase petitioner’s 1996 taxable income to reflect            
          income from the cancellation of the debt.  The proposed increase            
          resulted in an additional tax liability of $11,105 and the                  
          imposition of an accuracy-related penalty under section 6662 of             

               1    Unless otherwise indicated, section references are to             
          the Internal Revenue Code, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      

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