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Income Tax Keyed to Graetz
Zarin v. Commissioner
Citation:
92 T.C. 1084 (U.S.T.C. 1989)Facts
In 1978, Petitioner requested a line of gambling credit from a hotel he had been staying at, Resorts International Hotel, Inc. (Resorts). Resorts conducted an initial credit check and decided to issue Petitioner a line of $10,000. Resorts continued its credit arrangement until April 1980, when several of Petitioner’s personal checks bounced for insufficient funds. At this point, Petitioner had a debt of $3,435,000 outstanding with Resorts but ultimately settled with a payment arrangement for $500,000. The Commissioner of Internal Revenue asserted that the difference between Petitioner’s total debt of $3 million and the $500,000 settlement constituted income to Petitioner from the discharge of indebtedness.
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