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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 liabilities
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