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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).
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Last modified: May 25, 2011