David & Louise Zarin v. Commissioner of Internal Revenue. Appeal of David Zarin and Louise Zarin
Court of Appeals for the Third Circuit
1Opinion of the Court
OPINION OF THE COURT
COWEN, Circuit Judge.
David Zarin (“Zarin”) appeals from a decision of the Tax Court holding that he recognized $2,935,000 of income from discharge of indebtedness resulting from his gambling activities, and that he should be taxed on the income.1 This Court has jurisdiction to review the Tax Court’s decision under section 7482 of the Internal Revenue Code (1954) (the “Code”). After considering the issues raised by this appeal, we will reverse.
I
Zarin was a professional engineer who participated in the development, construction, and management of various housing projects. A…
2Cases cited9 opinions
- Commissioner v. TuftsSupreme Court of the United States · 1983
- Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
- Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
- Eleanor A. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Zarin v. CommissionerUnited States Tax Court · 1989
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3Cited by31 opinions
- Prudential Securities, Inc. v. Haugland, Texas Court of Appeals, 8th District (El Paso)1998
- Mark D. Collins v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
- Michael Friedman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2000
- Smith Ex Rel. Estate of Smith v. CommissionerCourt of Appeals for the Fifth Circuit · 1999
- Miller v. ZobyNew Jersey Superior Court Appellate Division · 1991
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