ZB, N.A. d/b/a Zions First National Bank v Crapo

Crapo appealed summary judgment to Zions arguing the 1099-C form issued by Zions created genuine issues of fact about whether his line of credit was discharged and whether Zions was estopped. The Court affirmed. It held the 1099-C is a piece of evidence that does not create any presumption of discharge or anything else and here, the form explicitly stated it was issued as a result of federal law requiring a form be issued when a debt was not paid for 36 months, the reasonable inference from the forgiven debt entries on the form is that the form was issued because of nonpayment as stated on the form and an internal charge off document issued by Zions actually requested further collection efforts and thus there was no proof of discharge. It rejected the estoppel argument on reliance grounds holding Crapo was required as a matter of law to inquire of Zions about whether the form was evidence of discharge before claiming the amount of debt as taxable income as the form stated on its face it was issued for nonpayment and thus no reasonable person would believe the debt had in fact been forgiven or otherwise discharged.