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TOBERMAN v. C.I.R.

No. 01-1398.

294 F.3d 985 (2002)

Gerald E. TOBERMAN and Nancy J. Toberman, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Submitted After Supplemental Briefing: April 22, 2002.

Filed: June 20, 2002.

Attorney(s) appearing for the Case

Daniel W. Schermer, argued, Minneapolis, MN, for appellant.

Kenneth W. Rosenberg, argued, DOJ, Washington, DC, for appellee.

BEFORE: BOWMAN, RICHARD S. ARNOLD, and HANSEN, Circuit Judges.

RICHARD S. ARNOLD, Circuit Judge.

Appellant Gerald E. Toberman1 appeals from a decision of the United States Tax Court upholding a determination by the Internal Revenue Service that he owed $1,194,503 in income tax and $238,900.60 in penalties for the tax year 1993. In reaching its decision, the Court held that in 1993 Mr. Toberman realized $2,781,810 in income from discharge of indebtedness, also known as cancellation-of-debt income,...

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