Key legal question
Whether the forgiven WEG principal amount constitutes taxable income for direct federal tax.
Extracted holding
Yes. The debt waiver created a taxable increase in net worth in the year the repayment obligation definitively lapsed.
Extracted reasoning
The original WEG advances were repayable loans; the waiver in 2009 replaced a genuine repayment obligation with an economic gain. The fact that the waiver was based on statutory conditions did not prevent taxation.