Zarin v. Commissioner
United States Tax Court
P, a compulsive gambler, gambled on credit extended by a New Jersey casino. During the following year, P and the casino settled the debt at a substantial discount. Held, the difference between the face amount of the debt and the amount for which it was settled constitutes income from the discharge of indebtedness. Sec. 61(a)(12), I.R.C. 1954.
1Opinion of the Court
OPINION
Cohen, Judge:
Respondent determined deficiencies of $2,466,622 and $58,688 in petitioners’ Federal income taxes for 1980 and 1981, respectively.
In the notice of deficiency, respondent determined that petitioners had income in 1980 from larceny by trick and deception. Respondent has abandoned that position. All of the other issues raised in the notice of deficiency have been settled. In his answer, respondent asserted that petitioners realized additional taxable income of $2,935,000 in 1981 through cancellation of indebtedness. The sole issue for decision is whether petitioners had…
2Cases cited29 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- James v. United StatesSupreme Court of the United States · 1961
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
24 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Borchers v. CommissionerUnited States Tax Court · 1990
- 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
- David & Louise Zarin v. Commissioner of Internal Revenue. Appeal of David Zarin and Louise ZarinCourt of Appeals for the Third Circuit · 1990
- Lair v. CommissionerUnited States Tax Court · 1990
19 more not listed; retrieve them via the Exa API.