Before going on to consider the interpretation of regulations pursuant to the debt forgiveness rules that have since been repealed, Paris J. applied a statement of a commentator that:
"The tax policy rationale for triggering a tax gain when a debt forgiveness occurs is that the debt enabled the debtor to acquire property or make expenditures that gave rise to deductions in computing income. To the extent that debt is forgiven, the cost of the expenditures has not been borne by the debtor, and should therefore not be recognized for tax purposes."