James Leo Armstrong - Page 4

                                        - 3 -                                         
          or bankrupt.                                                                
               By the beginning of 1997, the taxable year in issue,                   
          petitioner was (and had been for some time) in arrears in the               
          payment of his credit card balance with Mellon Bank.  Later that            
          year, under circumstances not disclosed in the record, Mellon               
          Bank forgave petitioner the debt, some $5,513, owed on his credit           
          card account.                                                               
               Petitioner was not insolvent in 1997, nor did he file for              
          bankruptcy during that year.                                                
               Mellon Bank issued to petitioner, and filed with respondent,           
          a Form 1099-C, Cancellation of Debt, reporting the cancellation             
          of indebtedness in 1997 in the amount of $5,513.  Petitioner did            
          not report any part of this amount on his Federal income tax                
          return for that year.                                                       
               Subsequently, respondent determined that petitioner failed             
          to report on his tax return for 1997 income from discharge of               
          indebtedness in the amount of $5,513.  Petitioner timely filed a            
          petition disputing respondent’s determination “due to the fact I            
          did not have an economic gain from the consideration.”                      
          Petitioner also attached to the petition a statement alleging               
          that the home improvement project he helped finance was producing           
          rent that was not being reported by the woman he had assisted.              
          Petitioner concluded his statement with the following offer:                








Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011