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NELSON v. COMMISSIONER

Docket No. 20811-95.

110 T.C. 114 (1998)

MEL T. NELSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 19, 1998.

Attorney(s) appearing for the Case

Neil M. Goff, for petitioner.

Virginia L. Hamilton, for respondent.

HAMBLEN, Judge:

Respondent determined a deficiency of $69,381 in petitioner's 1991 Federal income tax. After concessions, the principal issue for decision is whether discharge of indebtedness income realized and excluded from gross income under section 108(a)1 passes through to shareholders of a subchapter S corporation as an item of income in accordance with section 1366(a)(1)(A) and, in turn, increases the basis of the corporate...

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