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Respondent determined for 1999 a deficiency in petitioners’
Federal income tax of $420. After concessions,1 the issue
remaining for decision is whether petitioners failed to report
cancellation of indebtedness income in the amount of $1,372 for
taxable year 1999. Marianne Anderson has already conceded this
issue.
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. Petitioners
resided in Georgetown, Texas, at the time the petition was filed.
This case involves unreported cancellation of indebtedness
income. Charles Anderson (petitioner) provided a credit card for
a friend, Ms. Feathers, on his existing Citibank account.
Although the account was in his name, petitioner and Ms. Feathers
agreed she would be responsible for the debts she incurred.
The Citibank Card Agreement applicable to petitioner’s
account states “You may request additional cards on your account
for yourself or others and you may permit another person to have
access to the card or account number. However, if you
1 In the notice of deficiency respondent determined that
petitioners failed to report interest income in the amount of
$120 and dividend income in the amount of $3 for taxable year
1999. Petitioners have conceded these issues.
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