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assuming that there in fact was a discharge of indebtedness, the
only identifiable event fixing the time of the loss with any
certainty is the credit card company’s cessation of debt
collection activities in 1996, 3 years following petitioner’s
last payment. See Cozzi v. Commissioner, supra. There is
nothing in the record to indicate any event between 1996 and 1998
which would have altered the status of the account as collectible
or uncollectible. Based on the record before us, we find that
petitioners did not have discharge of indebtedness income during
1998.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
for petitioner.
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Last modified: May 25, 2011