Khen Thi and Hong Van Huynh - Page 6




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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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