Legal Opinion

Shannon v. Commissioner

United States Tax Court

Decided November 23, 1993No. Docket No. 25444-91UnpublishedCited by 4 opinions

1Opinion of the Court

SAMUEL G. SHANNON AND ELIZABETH SHANNON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Shannon v. Commissioner

Docket No. 25444-91

United States Tax Court

T.C. Memo 1993-554; 1993 Tax Ct. Memo LEXIS 553; 66 T.C.M. (CCH) 1418;

November 23, 1993, Filed

Decision will be entered for respondent.

For petitioners: Roger E. Grove.

For respondent: Thomas Rohall.

RAUM

RAUM

MEMORANDUM OPINION

RAUM, Judge: The Commissioner determined an income tax deficiency of $ 13,646 for petitioners' 1987 taxable year. At issue is whether income from discharge of indebtedness under section 61(a)(12) 1 was realized…

2Cases cited5 opinions

  1. Frentz v. CommissionerUnited States Tax Court · 1965
  2. J. William Frentz v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1967
  3. Walker v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1937
  4. White v. CommissionerUnited States Board of Tax Appeals · 1936
  5. Seay v. CommissionerUnited States Tax Court · 1974

3Cited by4 opinions

  1. Jelle v. CommissionerUnited States Tax Court · 2001
  2. Dennis and Dorinda J. Jelle v. CommissionerUnited States Tax Court · 2001
  3. Jelle v. CommissionerUnited States Tax Court · 2001
  4. Rivera v. CommissionerUnited States Tax Court · 1993

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