Chesapeake Outdoor Enters. v. Commissioner
United States Tax Court
C, an S corporation subject to the unified audit and litigation provisions of the Subchapter S Revision Act of 1982, Pub. L. 97-354, sec. 4(a), 96 Stat. 1691-1692, was insolvent within the meaning of sec. 108(d)(3), I.R.C., during its TYE Mar. 19, 1992. In that year, C realized cancellation of indebtedness (COD) income of approximately $<>995,000. Sec. 61(a)(12), I.R.C.
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C, an S corporation subject to the unified audit and litigation provisions of the Subchapter S Revision Act of 1982, Pub. L. 97-354, sec. 4(a), 96 Stat. 1691-1692, was insolvent within the meaning of sec. 108(d)(3), I.R.C., during its TYE Mar. 19, 1992. In that year, C realized cancellation of indebtedness (COD) income of approximately $<>995,000. Sec. 61(a)(12), I.R.C. In accordance with sec. 108(a), I.R.C., C excluded from its gross income the entire amount of COD income realized in that year. C asserts that such income is exempt from tax, and also that the characterization of such income…
1Opinion of the Court
CHESAPEAKE OUTDOOR ENTERPRISES, INC., ABEL TRUST, JOHN E. MAGEE, JR., TRUSTEE, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Chesapeake Outdoor Enters. v. Commissioner
Tax Ct. Dkt. No. 21830-96
United States Tax Court
T.C. Memo 1998-175; 1998 Tax Ct. Memo LEXIS 175; 75 T.C.M. (CCH) 2279;
May 12, 1998, Filed
Decision will be entered under Rule 155.
C, an S corporation subject to the unified audit and litigation provisions of the Subchapter S Revision Act of 1982, Pub. L. 97-354, sec. 4(a), 96 Stat. 1691-1692, was insolvent within the meaning of sec. 108(d)(3), I.R.C.,…
2Cases cited11 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Pyo v. CommissionerUnited States Tax Court · 1984
- Kluger v. CommissionerUnited States Tax Court · 1984
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Dial USA, Inc. v. CommissionerUnited States Tax Court · 1990
6 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Cronin v. CommissionerUnited States Tax Court · 1999
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