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On the basis of the foregoing, we hold that petitioner did
not realize discharge of indebtedness income with respect to the
loan default and abandonment of the collateral and that
petitioner is not liable for a section 6662 accuracy-related
penalty. We have considered all contentions that the parties
have raised. To the extent not addressed herein, those
contentions are without merit or unnecessary to reach.
To reflect the foregoing,
Decision will be entered for
petitioner.
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