Arguello v. Comr., T.C. Sum. Op 2012-99

(petitioner worked for investment business that entered into business relationship with another business to share customers and provide financing in return for web development work to investment business; petitioner ultimately spent $24,000 on used car that other business needed and co-signed credit card debt exceeding $35,000 for other business; by end of 2007, petitioner still owed $21,000 on car note and entered into agreement with other business that he would be paid $2,000 and that petitioner would forgive the $19,000 balance and be released as a co-signer; petitioner claimed $19,000 deduction on 2007 return; IRS denied deduction on basis that debt not worthless in 2007; court upheld IRS position because note not worthless in 2007 because it was forgiven not due to inability to pay but because made in exchange for petitioner's voluntary release as co-signer).