Timothy J. Coburn - Page 15

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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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