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1) The taxpayer was a shareholder in two corporations, one that processed fish meal and one that transported fish. He had loaned money to both corporations. 2) When the fish meal corporation was sold, the transport corporation cancelled the debt it was owed to allow the sale to proceed smoothly. The taxpayer then received cash for his loans and stock. 3) The court determined that the cancellation of debt was actually a capital contribution by the shareholders, not a worthless debt. Therefore, the taxpayer

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Scribd Government Docs

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