- 5 - outstanding debts were extinguished. During 2001, four of the notes were partially discharged by the following lenders: Initial Note Amount of Debt Creditor Amount Canceled Household $111,200 $62,707 Finance Countrywide 127,200 74,670 Home Loans Superior 111,200 103,171 Federal Bank Washington 111,200 75,615 Mutual The Household Finance debt was canceled on April 27, 2001, and the Superior Federal Bank debt was canceled on March 1, 2001. The remaining debts listed were canceled in 2001. Petitioners did not include the amounts of debts canceled as income in their 2001 joint Federal income tax return. Petitioners reported a total income in 2001 of $78,416, comprising mostly wages. On December 29, 2003, respondent issued petitioners a notice of deficiency for the taxable year 2001. Respondent determined that the amounts of canceled debt from Countrywide Home Loans, Superior Federal Bank, and Washington Mutual should have been included in petitioners’ gross income. Respondent did not include the canceled debt of $62,707 from Household Finance in the notice of deficiency but raised it at trial through the stipulation of related exhibits without explaining that it was aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011