Legal Opinion
Gerald E. Toberman and Nancy J. Toberman v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided June 20, 2002No. 01-1398PublishedCited by 7 opinions
1Opinion of the Court
RICHARD S. ARNOLD, Circuit Judge.
Appellant Gerald E. Toberman 1 appeals from a decision of the United States Tax Court upholding a determination by the Internal Revenue Service that he owed $1,194,503 in income tax and $238,900.60 in penalties for the tax year 1993. In reaching its decision, the Court held that in 1993 Mr. Toberman realized $2,781,810 in income from discharge of indebtedness, also known as cancellation-of-debt income, that Mr. Toberman did not establish that he. was insolvent, so as to come under the insolvency exception to this sort of income, that the taxpayer did not…
2Cases cited5 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Commissioner v. TuftsSupreme Court of the United States · 1983
- Bennett Paper Corporation and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1983
- David D. Parrish v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1999
- John D. Askew and Nona B. Askew v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1986
3Cited by7 opinions
- Educational Credit Management Corp. v. BronsdonDistrict Court, D. Massachusetts · 2009
- Arroyo v. United States Department of Education (In Re Arroyo)United States Bankruptcy Court, D. Massachusetts · 2012
- Brooks v. Comm'rUnited States Tax Court · 2012
- In Re Pt-1 Communications, Inc.United States Bankruptcy Court, E.D. New York · 2011
- Koziej v. Comm'rUnited States Tax Court · 2010
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