This Casenote examines Zarin v. Commissioner, decided by the United States Court of Appeal for the Third Circuit in 1990. This case considered exceptions to the general rule that income from the discharge of indebtedness is included as gross income under the Internal Revenue Code. The court found these exceptions valid. This Casenote argues that the court's reasoning in Zarin v. Commissioner assures that its decision will have implications well beyond the facts of the case. The author also suggests that these exceptions are both reinforced and expanded by this case. He concludes that the result of this case is a more flexible approach to disputed liability issues, which should engender more rational decisions in the tax law area.
Jon D. Rigney,
Zarin v. Commissioner: The Continuing Validity of Case Law Exceptions to Discharge of Indebtedness Income,
San Diego L. Rev.
Available at: https://digital.sandiego.edu/sdlr/vol28/iss4/9