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Finding herself in default on the mortgage loan secured by her New Jersey home, Carol Callahan enlisted the help of a company which had sent her an unsolicited mailing, offering to help individuals in her situation save their real property from foreclosure. While the company (REI) did successfully negotiate a discounted payoff of her mortgage loan, it also convinced her to convey her house to an affiliate and ended up keeping more than half of the purported sale proceeds for itself. Then, after a New Jersey court decision gave Callahan her house back and things were finally starting to look up for her, the IRS came in and contended that she had recognized both gain and COD income. In a recent decision, the Tax Court declined to end Callahan's tale of woe, but did give her a little good news.

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