Legal Opinion

Zarin v. Commissioner

United States Tax Court

Decided May 22, 1989No. Docket No. 21371-86Published

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

David Zarin and Louise Zarin, Petitioners v. Commissioner of Internal Revenue, Respondent

Zarin v. Commissioner

Docket No. 21371-86

United States Tax Court

92 T.C. 1084; 1989 U.S. Tax Ct. LEXIS 75; 92 T.C. No. 68;

May 22, 1989. May 22, 1989, Filed

Decision will be entered under Rule 155.

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.…

Also in this document: Dissent · Tannenwald; Dissent · Jacobs; Dissent · Ruwe.

2Cases cited49 opinions

  1. Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
  2. Richards v. United StatesSupreme Court of the United States · 1962
  3. Commissioner v. DubersteinSupreme Court of the United States · 1960
  4. Eisner v. MacOmberSupreme Court of the United States · 1920
  5. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955

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