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WITZEL v. COMMISSIONER

Docket No. 6592-97.

77 T.C.M. 1487 (1999)

T.C. Memo. 1999-64

William C. Witzel and Gene E. Witzel v. Commissioner.

United States Tax Court.

Filed March 4, 1999.

Attorney(s) appearing for the Case

Wayne A. Cooper, for the petitioners. John O. Walsh, for the respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

Respondent determined a deficiency of $602,119 in petitioners' 1993 Federal income tax.

After concessions,1 the sole issue for decision is whether discharge of indebtedness (COD) income excluded under section 108(a) from the gross income of an S corporation passes through to the shareholder of the S corporation as an item of income under section 1366(a)(1)(A) and consequently increases...

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