MEMORANDUM OPINION
WELLS, Judge:
Respondent determined a deficiency in petitioner's 2000 Federal income tax of $277,951 and a section 6662 accuracy-related penalty of $55,590.20. The issue to be decided is whether petitioner must recognize discharge of indebtedness income in 2000 with respect to a loan on which petitioner defaulted. Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references...
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