Description
NOTES 915 Tax Lawyer, Vol. 55, No. 3 NOTE DISCHARGE OF NONRECOURSE LIABILITY VERSUS DISCHARGE OF THIRD PARTY INDEBTEDNESS: FRIEDLAND V. COMMISSIONER In Friedland v. Commissioner,1 the Tax Court held that the amount realized on a sale or disposition of property under section 1001(b) does not include the value of any indebtedness discharged on behalf of a third party. The taxpayer transferred appreciated stock to a bank in exchange for the discharge of his adult son’s indebtedness to the bank.2 The...

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