- 9 - principle that a taxpayer does not escape taxation on what is otherwise the taxpayer’s income merely because the income was paid directly to the taxpayer’s creditor. Helvering v. Horst, 311 U.S. 112 (1940); Parkford v. Commissioner, 133 F.2d 249, 251 (9th Cir. 1943).7 Furthermore, we think it appropriate to note that, contrary to petitioner’s arguments, the above-described bankruptcy proceedings are, for the most part, irrelevant. The bankruptcy court did not focus on the nature of the reward as an item of income but rather as an asset available as a source of payment to petitioner’s creditors. See Parkford v. Commissioner, supra at 251. Similarly, petitioner’s reliance on Cold Metal Process Co. v. Commissioner, 17 T.C. 916 (1951), affd. per order 53-1 USTC par. 9135 (6th Cir. 1952), Barnette v. Commissioner, T.C. Memo. 1992-371, affd. without published opinion 41 F.3d 667 (11th Cir. 1994), Stone v. Commissioner, T.C. Memo. 1984-187, Collins v. Commissioner, T.C. Memo. 1972-170, and Hannaford v. Commissioner, 7 Curiously, and if only by implication, petitioner recognizes this principle as she argues in the alternative that to the extent that the reward is includable in her income, it should be includable in her 1998 income because that was the year Proulx’s lien arose. A creditor’s collection rights against a taxpayer’s property, however, say little about when a cash basis taxpayer realizes income.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007