Gerald A. Bunker - Page 4

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          portions of indebtedness owing on petitioner’s credit cards in              
          the event of death, disability, or unemployment.2                           
               Due to the Defense Base Closure and Realignment Commission             
          which closed Kelly AFB in 2001, petitioner lost his employment at           
          Kelly AFB on November 6, 2000.  Because of petitioner’s                     
          unemployment, petitioner satisfied one of the contingencies                 
          provided by the credit card insurance policies he carried.  Thus,           
          petitioner applied for insurance benefits pursuant to the credit            
          card insurance policies from American Security and Capital One.             
          Petitioner remained unemployed for most of 2001.  Accordingly,              
          payments were made during 2001 by American Security and Capital             
          One to the banks that had issued the credit cards in partial                
          payment of amounts due by petitioner on his credit cards.  During           
          2001, petitioner owed approximately $45,000 in credit card debt.            
               Pursuant to the terms of the credit card insurance                     
          contracts, American Security paid $11,396 to the applicable bank            
          in partial payment of petitioner’s credit card debt and Capital             
          One paid $4,448 to the applicable bank in partial payment of                
          petitioner’s credit card debt.  As a result of paying                       
          petitioner’s credit card obligations, American Security and                 
          Capital One reported these payments to the Internal Revenue                 




          2The record does not reflect the amounts paid as premiums                   
          for such insurance or how such premiums were paid.                          




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