ORDER AND JUDGMENT*
TERRENCE L. O'BRIEN, Circuit Judge.
The Commissioner of Internal Revenue assessed an income tax deficiency of $171,631 against Bill and Carolyn McGowen for the 2004 tax year. He determined the taxpayers' joint federal income tax return mischaracterized proceeds from the termination of a life insurance contract as a discharge of a debt and therefore improperly excluded the gain from the taxpayers' income...
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