- 4 - petitioner and to the Internal Revenue Service a Form 1099-C, Cancellation of Debt, reporting discharge of indebtedness income in the amount of $19,866.70. On April 21, 1999, petitioner sent the Form 1099-C back to MBNA with a cover letter in which he stated, among other things: The debt was never a “forgiveness” of anything, but as you know a compromise of many issues of a vague, doubtful, and disputed claim. * * * I stopped my payments to you after many accusations on both sides, and after a period of time, I was offered a complete settlement of the account for $17,500. After considerable negotiations, a settlement was effected of $12,750 [sic]. This was to save us both a law suit and legal expense, as well as an equitable conclusion of your improper handling of my account. Petitioner attached to his 1998 tax return a statement as follows: No amounts pursuant to the attached 1099 have been included in individual income. The cancellation should be characterized as a compromise of a doubtful and disputed claim. No deductions were taken for these expenditures. Respondent determined that petitioner received cancellation of indebtedness income in 1998 in the amount of $19,866.70. Respondent also determined that petitioner had unreported interest income of $128 and adjusted petitioner’s taxable Social Security income. Petitioner did not in his petition or at trial dispute the interest or Social Security income adjustments. He is thus deemed to have conceded them.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011