- 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 DistrictPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011