Chesapeake Outdoor Enterprises, Inc., Abel Trust, John E. Magee, Jr., Trustee, Tax Matters Person v. Commissioner

T.C. Memo. 1998-175

UNITED STATES TAX COURT CHESAPEAKE OUTDOOR ENTERPRISES, INC., ABEL TRUST, JOHN E. MAGEE, JR., TRUSTEE, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21830-96. Filed May 12, 1998. 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.…