ZARIN v. C.I.R.

No. 90-1240.

916 F.2d 110 (1990)

David & Louise ZARIN v. COMMISSIONER OF INTERNAL REVENUE. Appeal of David ZARIN and Louise Zarin.

United States Court of Appeals, Third Circuit.

Decided October 10, 1990.


Attorney(s) appearing for the Case

William M. Goldstein (argued), Theodore P. Seto, Drinker, Biddle & Reath, Philadelphia, Pa., for appellants.

Bruce Ellisen (argued), Gary R. Allen, U.S. Dept. of Justice, Tax Div., Washington, D.C., for appellee.

Before STAPLETON, COWEN and WEIS, Circuit Judges.


OPINION OF THE COURT

COWEN, Circuit Judge.

David Zarin ("Zarin") appeals from a decision of the Tax Court holding that he recognized $2,935,000 of income from discharge of indebtedness resulting from his gambling activities, and that he should be taxed on the income.1 This Court has jurisdiction to review the Tax Court's decision under section 7482 of the Internal Revenue Code (1954) (the "Code"). After considering the issues...

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