- 4 - First Madisonville made unsuccessful attempts to collect on the final renewal note. Efforts to foreclose on the security were frustrated by another creditor with priority with respect to the pledged assets. Consequently, the bank determined that it would not be financially worthwhile to pursue legal action against petitioner or the corporation. In 1997, First Madisonville determined that the final renewal note was uncollectible and issued to petitioner a Form 1099-C, Cancellation of Debt, which reported discharge of indebtedness income of $51,792 for that year (the Form 1099-C income). Petitioner filed a 1997 Form 1040, U.S. Individual Income Tax Return. Petitioner did not report the Form 1099-C income on that return. In a notice of deficiency dated October 20, 1999, respondent determined a deficiency in petitioner’s 1997 Federal income tax. Among other adjustments made in the notice of deficiency, respondent increased petitioner’s 1997 income by the amount of the Form 1099-C income. Petitioner did not petition this Court in response to that notice and the deficiency and related amounts were assessed in due course. On October 24, 2001, respondent mailed to petitioner a final notice of intent to levy with respect to his outstanding 1997 Federal income tax liability.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011