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HAHN, JR. v. COMMISSIONER

Dkt. No. 23756-04.

93 T.C.M. 1055 (2007)

T.C. Memo. 2007-75

Gilbert Hahn, Jr. and Margot H. Hahn. v. Commissioner.

United States Tax Court.

April 2, 2007.

Attorney(s) appearing for the Case

George B. Delta and Stuart H. Gary, for petitioner Gilbert Hahn, Jr.

Mary M. Baker, Matthew S. Campbell, James R. Hagerty, and Haig V. Kalbian, for petitioner Margot H. Hahn.

Cleve Lisecki, Veena Luthra, and Lindsey D. Stellwagen, for respondent.

MEMORANDUM OPINION

WELLS, Judge:

The instant matter is before the Court on petitioner Gilbert Hahn, Jr.'s Motion for Partial Summary Judgment.1 The issue for decision concerns discharge of indebtedness income pursuant to section 61(a)(12). For the reasons stated below, we shall deny petitioner's motion. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references...

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