Kleber v. Comr., T.C. Memo. 2011-233

(petitioner leased farmland from U.S. Navy for $191,520 annual rent, but later failed to make rent payments and notified Navy via letter that petitioner could no longer continue farming; Navy agreed to terminate lease and determined amount of past-due rent of over $200,000; debt later determined to be uncollectible and debt written off and 1099-C issued to petitioner showing CODI of $263,587 that petitioner did not report on tax return for year at issue; IRS failed to prove that petitioner's had CODI with respect to lease for year at issue (2006) because no evidence of substantive collection activities that occurred; from 1999 to 2006, petitioner never received any correspondence with respect to any debt pursuant to the lease; petitioner not liable for accuracy-related penalty). 

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