Thomas E. Roberts - Page 5

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               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.                                               







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