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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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Last modified: May 25, 2011