- 2 -
is not reviewable by any other court, and this opinion should not
be cited as authority.
Respondent determined a deficiency in petitioners’ Federal
income tax for 2003 in the amount of $1,950.
The sole issue for decision is whether petitioners should
have included $7,807 of cancellation of indebtedness income on
their 2003 Federal income tax return. We hold that they should
have done so and therefore sustain respondent’s determination.
Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and accompanying exhibits.
At the time the petition was filed, Stephen Bernard
Schachner (Mr. Schachner) and Jill Frances Schachner (jointly
petitioners) lived in Charlotte, North Carolina.
In 1994, while Mr. Schachner was taking classes at a local
community college, he borrowed $10,030 from University Support
Services to purchase an Apple computer (the Apple loan). At Mr.
Schachner’s request, his mother-in-law applied for the loan on
his behalf, and both Mr. Schachner and his mother-in-law signed
the Application & Promissory Note, agreeing to be jointly and
severally liable for the loan.
In 1995, petitioners filed a Chapter 13 bankruptcy petition
with the United States Bankruptcy Court for the Western District
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011