David O. Alegria - Page 3

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          be entered is not reviewable by any other court, and this opinion           
          should not be cited as authority.                                           
               Respondent determined a deficiency in petitioner’s Federal             
          income tax for the taxable year 2001 of $9,427 and an accuracy-             
          related penalty under section 6662(a) of $1,885.                            
               The issues for decision are:                                           
               (1)  Whether petitioner received unreported discharge of               
          indebtedness income of $31,327 in taxable year 2001.  We hold               
          that he did.                                                                
               (2)  Whether petitioner is liable under section 6662(a) for            
          an accuracy-related penalty.  We hold that he is not.                       
               Adjustments to the amount of petitioner’s itemized                     
          deductions, child tax credit, and alternative minimum tax are               
          purely computational matters, the resolution of which is                    
          dependent on our disposition of the first disputed issue.                   
                                     Background                                       
               Some of the facts have been stipulated, and they are so                
          found.  We incorporate by reference the parties’ stipulation of             
          facts and accompanying exhibits.                                            
               At the time that the petition was filed, petitioner resided            
          in Topeka, Kansas.                                                          
               In 1984, petitioner obtained a credit card from MBNA America           
          Bank (MBNA), which he used on occasion over the next 15 years.              







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