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KLEBER v. COMMISSIONER OF INTERNAL REVENUE

No. 1545-09.

T.C. Memo. 2011-233

THOMAS AND MONICA L. KLEBER, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 28, 2011.

Attorney(s) appearing for the Case

David R. Emerich , for petitioner.

Christina E. Ciu , for respondent.

MEMORANDUM OPINION

HAINES, Judge.

Respondent determined a deficiency in petitioners' Federal income tax for 2006 of $86,441 and a penalty under section 6662(a) of $17,288.1 The issues for decision are: (1) Whether petitioners are required to include in income $263,587 of cancellation of indebtedness income (COI income) for taxable year 2006 as reported by the Defense Finance and Accounting Services (DFAS); (2) if so, whether...

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