- 7 - indebtedness income is excludable from gross income pursuant to section 108(a)(1)(A).6 We have considered all arguments raised by the parties. Arguments not addressed herein are moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered for petitioners. 6 In their prayer for relief, petitioners requested the Court to redetermine their deficiency. Petitioners have not requested the Court to determine the existence of any overpayment resulting from their inclusion of $25,116 of discharge of indebtedness in gross income. We deem petitioners to have waived any claim to any overpayment. See Rule 34(b)(6); Horn v. Commissioner, 90 T.C. 908, 944 (1988).Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011