(petitioner borrowed $78,849.07 from employer in return for promissory notes; petitioner to repay loans via his compensation incentives with employer also paying taxes on incentives; loan lacked repayment date and did not specify interest; petitioner made no payment on loan; and petitioner within two years, employer sold out to another business and new employer issued petitioner Form 1099-Misc. denoting amount of loan and reporting loan as non-employee compensation; IRS took position that petitioner received constructive bonus that was then used to repay loan; petitioner disagreed with IRS position and claimed loan was either canceled or that he was insolvent at time of cancellation; Tax Court determined that amount reported on Form 1099-Misc. was cancellation of debt income and 1099-Misc. issued in error; petitioner's liabilities exceeded assets by over $20,000 thereby reducing amount of CODI, which was $56,207.65).