Ingo H. Jensen - Page 6

                                        - 6 -                                         
          whether an erroneous Form 1099-C had been issued because the debt           
          discharged was nonrecourse (the erroneous Form 1099-C issue).               
          Mr. Tkacik requested information to support this argument as well           
          as reiterated respondent’s request for documentation regarding              
          the insolvency issue.  Some documentation was forwarded to Mr.              
          Tkacik on March 31, 1999.  Mr. Tkacik found the documentation               
          failed to prove petitioner’s insolvency and did not address the             
          erroneous Form 1099-C issue.  Additional documentation was                  
          received by Mr. Tkacik on April 13, 1999.  Mr. Tkacik found that            
          this additional documentation again failed to substantiate the              
          insolvency claim and failed to address the erroneous Form 1099-C            
               Finally, in a conference call conducted on April 16, 1999,             
          Mr. Battagline set forth arguments of law and facts sufficient to           
          set the basis for determining that the Form 1099-C was erroneous.           
          On April 22, 1999, Mr. Battagline filed a motion for leave to               
          amend petition and motion for continuance of trial, which the               
          Court granted.                                                              
               Correspondence resumed between the parties beginning July              
          14, 1999.  Mr. Battagline provided Mr. Tkacik with legal                    
          arguments establishing that the canceled debt was nonrecourse.              
          Mr. Tkacik reached the same conclusion and, on September 8, 1999,           
          informed Mr. Battagline.                                                    

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011