Charles & Marianne T. Anderson - Page 4

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          do, you must pay us for all charges made by those persons,                  
          including charges for which you may not have intended to be                 
          responsible.”                                                               
               As petitioner received billing statements detailing charges            
          to the account, he forwarded them to Ms. Feathers for payment.              
          Ultimately, Ms. Feathers incurred $4,574.93 in charges on the               
          credit card.                                                                
               Petitioner was subsequently contacted by a collection agency           
          on behalf of Citibank.  He was informed of the $4,574.93                    
          delinquent balance and was offered the opportunity to settle the            
          debt.  In July 1999 petitioner settled the outstanding debt for             
          $3,202.45, or 70 percent of the total value.  Citibank reported             
          $1,372 as cancellation of indebtedness income to respondent on              
          Form 1099-C, Cancellation of Debt.  Petitioners did not report              
          this income on their joint income tax return.  Petitioner denied            
          receiving a Form 1099-C reporting the amount of debt discharged.            
               Petitioner disputes having income from the discharge of                
          $1,372 of the debt and, raising a variety of arguments, contends            
          that a discharge of indebtedness does not constitute gross                  
          income.                                                                     
                                     Discussion                                       
               Respondent's determinations in the notice of deficiency are            
          presumed correct, and, generally, petitioners must prove those              
          determinations wrong in order to prevail.  Rule 142(a)(1); Welch            






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