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Income Tax Keyed to Bankman
Zarin v. Commissioner
Citation:
916 F.2d 110 (3d Cir. 1990)Facts
Beginning in 1978, Petitioner started gambling at Resorts International Hotel’s casino and receiving lines of credit from the casino to fund his high-stakes gambling trips. In late 1979, the New Jersey Casino Control Commission instituted a complaint against the casino and instituted an emergency order to effectively make illegal any further extensions of credit to Petitioner.
The casino continued to extend credit to Petitioner until he could no longer pay his debts in 1980. In that year, the casino sued Petitioner for his outstanding debts totaling $3,435,000 and the parties later settled out of court for $500,000. The Commissioner of Internal Revenue asserted a deficiency against Petitioner, finding that the discharged debt from the settlement, $2,935,000, constituted taxable income.
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