Walter James Sims, Jr. & Sonia Gail Tolliver-Sims - Page 3




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               Respondent determined a deficiency in petitioners’ Federal             
          income tax of $743 for the taxable year 1998.                               
               The sole issue for decision is whether petitioners received            
          unreported discharge of indebtedness income in taxable year 1998.           
          Respondent’s adjustment to the amount of Social Security benefits           
          includable in petitioners’ gross income is computational and will           
          be resolved by our holding on the issue in this case.                       
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Philadelphia, Pennsylvania, on the date the petition was filed in           
          this case.                                                                  
               Petitioner husband (petitioner) applied for and received a             
          Discover credit card in 1986.  At this time, petitioner resided             
          in Philadelphia and shared an address with his mother.  In the              
          following year, petitioner moved to Camden, New Jersey.                     
          Petitioner remained at this address until 1997 when he married              
          petitioner wife and returned to a different address in                      
          Philadelphia.  During 1999, petitioner’s mother changed her                 
          mailing address from the address she had previously shared with             
          petitioner.                                                                 
               The records of the financial institution holding                       
          petitioner’s credit card account indicate that as of April 8,               
          1998, the credit card balance was $3,103.91.  The company’s                 






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