- 5 - 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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011