The petitioner was a doctor that was recruited to work for a hospital in a rural area and was offered a $260,000 loan to work for the hospital with the loan forgiven upon the satisfaction of certain goals. The goals were met and the loan was forgiven over a four-year timespan. The petitioner didn't report any income from the forgiveness and the IRS asserted a tax deficiency. The court agreed with the IRS. The petitioner argued that because the loan was non-recourse that he wasn't personally liable for repayment and, thus, didn't have income upon forgiveness. The court noted that the loan terms made him liable and also rejected the petitioner's argument that the nature of the loan meant that he couldn't have cancelled debt income. While the hospital issued the petitioner a Form 1099-Misc. rather than a Form 1099-C, the court held that was merely a bookkeeping error that had no bearing on the tax effect of the forgiveness. Wyatt v. Comr., T.C. Sum. Op. 2015-31.