Memorandum Opinion
TANNENWALD, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the year 1983 in the amount of $44,450. The issue for decision is whether petitioners realized discharge of indebtedness income from the discharge of a second deed of trust, or in the alternative, whether the tax benefit rule applies to the deductions taken in the taxable years 1980 through 1983 for interest expense and finance charges paid during...
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