The petitioner defaulted on a car loan in 2005 with the car also being repossessed that year. After the car was sold, an unpaid balance remained on the loan. The lender submitted the account balance due to five collection agencies over several years to collect. However, the balance due on the loan was not able to be collected. In 2011, the lender wrote cancelled the debt and issued Form 1099-C to the petitioner in 2011. The petitioner had moved, however, and the 1099-C was returned as undeliverable. The petitioner did not report the income from the discharged debt on the 2011 return. The IRS received a copy of the 1099-C and sought to collect the amount from the petitioner as income that should have been reported on the 2011 return. While the petitioner argued that the income wasn't reportable due to the lack of receiving Form 1099-C, that argument failed. However, the petitioner also argued that the income should have been reported in 2008 which was a tax year now closed. The petitioner reached that conclusion based on the instructions for Form 1099-C which create a rebuttable presumption that an identifiable event has occurred during a calendar year if a creditor has not received a payment on a debt at any time during a testing period ending at the close of the year. The testing period is a 26-month period. The last payment date on the loan was June 20, 2005, and the 36-month period expired on June 20, 2008. The IRS bore the burden of proof under I.R.C. Sec. 6201(d) and was required to produce evidence of more than just receipt of Form 1099-C because the petitioner raised a reasonable dispute at the accuracy of the 1099-C and cooperated with the IRS. Clark v. Comr., T.C. Memo. 2015-175.