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Plotinsky v. Commissioner

T.C. Memo. 2008–244 (2008)

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Plotinsky v. Commissioner

United States Tax Court
T.C. Memo. 2008–244 (2008)

Facts

Key Bank USA/American Education Services (AES) offered student-loan-consolidation services. To encourage borrowers to consolidate their student loans with AES, the company offered an on-time-payment incentive program. Under the program, borrowers who consolidated their loans through AES and made 36 consecutive on-time monthly payments would have a portion of their loans discharged. In August 2001, David Plotinsky (plaintiff) consolidated his federal student loans through AES. In 2004, after Plotinsky satisfied the program’s conditions, AES discharged $3,043 of Plotinsky’s loan balance. AES issued Plotinsky a Form 1099-C, Cancellation of Debt, for the amount discharged. However, Plotinsky did not report this amount as income on his 2004 federal income tax return. Instead, he attached a written statement asserting that he was not reporting the cancellation as income because, in his opinion, it constituted a gift rather than income. The commissioner of the Internal Revenue Service (defendant) assessed a deficiency. Plotinsky filed a petition with the United States Tax Court challenging the commissioner’s determination.

Rule of Law

Issue

Holding and Reasoning (Chiechi, J.)

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