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COZZI v. COMMISSIONER

Docket No. 24208-84.

88 T.C. 435 (1987)

JOHN R. COZZI AND ANTOINETTE V. COZZI, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 18, 1987.

Attorney(s) appearing for the Case

Richard M. Lipton, Jeffrey G. Liss, and Ronald L. Boorstein, for the petitioners.

Andrew P. Fradkin and Thomas C. Borders, for the respondent.

SIMPSON, Judge:

The Commissioner determined a deficiency of $26,991 in the petitioners' Federal income tax for 1980 and an addition to tax of $1,350 under section 6653(a) of the Internal Revenue Code of 1954.1 The issues for decision are: (1) Whether the petitioners realized ordinary income in 1980 as a result of the discharge of debt owed by a partnership in which they were limited partners; and (2) whether the petitioners are...

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