Stewart v. Comr., T.C. Sum. Op. 2012-46

(petitioner defaulted on credit card; debt charged off on 9/12/96 and collection agency subsequently acquired account which was later acquired by another collection agency on 12/28/07; automated attempts to collected continued until 2008 even though statute of limitations for collection had expired on 2/15/01; collection agency issued Form 1099-C for 2008 tax year for $8,570.71, but petitioner's tax return did not report CODI; court determined that debt discharged in 1999, the year it became clear that debt would not be repaid - 36-month nonpayment period; issuance of Form 1099-C not determinative of discharged debt).