- 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