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SHANNON v. COMMISSIONER

Docket No. 25444-91.

66 T.C.M. 1418 (1993)

T.C. Memo. 1993-554

Samuel G. Shannon and Elizabeth Shannon v. Commissioner.

United States Tax Court.

Filed November 23, 1993.

Attorney(s) appearing for the Case

Roger E. Grove, for the petitioners. Thomas Rohall, for the respondent.

Memorandum Opinion

RAUM, Judge:

The Commissioner determined an income tax deficiency of $13,646 for petitioners' 1987 taxable year. At issue is whether income from discharge of indebtedness under section 61(a)(12)1 was realized in 1986 or 1987. Petitioners also have attempted to raise an additional issue, in the event that we find that the income was realized in 1987, namely, whether the income was attributable to a passive activity...

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