Title
910--GRAYSON 329-338
By
PageMaker 7.0
Description
NOTES 329 Tax Lawyer, Vol. 55, No. 1 NOTE AN EXAMINATION OF THE SECTION 108 STATUTORY INSOLVENCY EXCLUSION AND ITS DEFINITION OF “ASSETS” AS APPLIED IN CARLSON V. COMMISSIONER In Carlson v. Commissioner1 the Tax Court held that Roderick E. Carlson, a commercial fisherman, and his wife Jeannette Carlson (the “taxpayers”) could not exclude discharge of indebtedness (DOI) income from gross income under the statutory insolvency exclusion of section 108(a)(1)(B). Holding that the term “assets,” as...

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