Timothy C. Robbins - Page 7

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          $144,000 in 2000 and about the same in 2001.  He had at least a             
          50-percent interest in his principal residence and the building             
          where his firm was located.  Additionally, he had at least a 25-            
          percent interest in a cabin during 2001.  Although petitioner had           
          credit card debt in addition to the balance with MBNA, the                  
          evidence presented does not satisfy the Court that these other              
          liabilities exceeded the value of his assets.  On this record,              
          the Court holds that petitioner was not insolvent during 2001               
          and, therefore, must include as gross income the $6,384 discharge           
          of indebtedness reported by MBNA.  Respondent, therefore, is                
          sustained.                                                                  
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


          Decision will be entered                                                    
                         for respondent.                                              



















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