On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Hohl et al. v. Commissioner (T.C. Memo. 2021-5). The issue presented in Hohl et al. v. Commissioner was whether failure to repay loans provided to a partnership by a partner, which the partnership treated as contributions upon dissolution, resulted in cancellation of indebtedness income. Background to Hohl et al. v. Commissioner Hohl, Blake, and Bowles were partners in a partnership