- 5 - Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 430 (1955); see also Roemer v. Commissioner, 716 F.2d 693, 696 (9th Cir. 1983), revg. 79 T.C. 398 (1982) (all realized accessions to wealth are presumed taxable income, unless the taxpayer can demonstrate that an acquisition is specifically exempted from taxation). Moreover, section 61(a)(12) provides that gross income includes income from discharge of indebtedness. The record reflects that petitioners made substantial purchases on their credit cards during 1996 and 1997. Petitioners received goods or services for these purchases and, therefore, realized economic benefits from such purchases. Moreover, these purchases were paid for through the credit made available to petitioners from the credit cards. These credit card purchases, therefore, provided petitioners with a source of money or capital in order to make those purchases. The interest charged on each credit card represented the charge to petitioners for the use of that money or capital. The available credit, therefore, was an economic benefit petitioners received. Finally, the insurance premiums charged to the credit cards provided additional economic benefits to petitioners if certain conditions occurred, such as death, disability, or unemployment. The unemployment condition did occur, and petitioners as a result realized economic benefits by the amount of the payments the insurance companies paid on petitioners' credit card liabilitiesPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011