discharge of a debt

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The fact that the discharge of a debt is voluntary does not establish that such forgiveness is a gift.
Moreover, the court prescribed a modern alternative theory under which the discharge of a debt for less than face is income to the debtor, because the borrowed funds were excluded from the debtor's gross income when first received; on relief from the obligation, "the basis for the original exclusion thus evaporates" (Centennial Savings Bank FSB, 499 US 573 (1991); see also Tufts, 461 US 300 (1983)).