Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined a deficiency of $13,544 in petitioners' Federal income tax for 1988. The issue for decision is whether petitioners realized income in the amount of $31,675 from the discharge of indebtedness pursuant to section 61(a)(12), as determined by respondent. Unless stated otherwise, all section references are to the Internal Revenue Code as in effect during 1988.
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