- 2 - The sole issue for decision is whether petitioners realized discharge of indebtedness income under section 61(a)(12) and, if so, the extent thereof under section 108(a). Some of the facts were stipulated. Those facts and the accompanying exhibits are so found and are incorporated herein by reference. Petitioners’ legal residence at the time the petition was filed was Detroit, Michigan. Henry B. Martins (petitioner) was an engineer for the Ford Motor Co., an automobile manufacturer, during the year at issue. Petitioner was also engaged in a separate activity wherein he arranged the purchase and sale of goods from overseas sources to customers in the United States. The goods he dealt with were generally electronic equipment, food service equipment, and other equipment for which there was a demand and the availability of an overseas source for its acquisition. Petitioner’s practice was to purchase the equipment and, upon delivery to the customer, collect the selling price. His purchases were all financed through his American Express credit card. At some point, petitioner was faced with a problem in collecting payments on equipment he had delivered. As a result, he was unable to pay his account with American Express and was classified as delinquent. As of July 17, 2002, petitioner owed American Express $24,831.38. Petitioner made several payments in the ensuing months that reduced his indebtedness to $21,831.38. AtPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011