Crapo v. Zions Bank, 394 P.3d 338

Shayne Crapo borrowed $250,000 under a home-equity line from Zions First National Bank, made payments through Sept. 2010, then defaulted; Zions accelerated the loan and created an internal Charge Off Request transferring the account to its Recovery Department.
After 36 months with no payments, Zions issued IRS Form 1099‑C (dated 12/31/2013) showing Identifiable Event Code H and listing "FORGIVEN DEBT AMT 3 YRS NO PAYMENT" and $250,000 as the amount discharged; Crapo says he reported that amount on his 2013 tax return.
Zions sued for the loan deficiency; at summary judgment the district court entered judgment for Zions, rejecting Crapo's claims that the 1099‑C established (1) actual discharge of the debt and (2) estoppel against collection.
The IRS regulation at issue treats certain "identifiable events" (including Code H, the 36‑month nonpayment rule) as triggering 1099‑C reporting even when no actual discharge occurred; the Form itself warns that receipt may not mean the debt was actually discharged.
The Utah Supreme Court reviewed de novo whether the evidence (chiefly the 1099‑C and internal bank documents) created a genuine issue of material fact as to actual discharge or estoppel, and whether Zions was entitled to attorney fees.

Issue	Plaintiff's Argument (Crapo)	Defendant's Argument (Zions)	Held
Whether the 1099‑C creates a genuine issue that the debt was actually discharged	The Form 1099‑C (and its "FORGIVEN DEBT" description) is prima facie proof of discharge; at minimum it creates a factual dispute	The 1099‑C was issued under Code H (36‑month nonpayment reporting) and, read in context, does not prove an actual forgiveness	Court: No genuine dispute — the form, showing Code H and date, indicates reporting under the nonpayment rule, and absent other evidence a reasonable finder could not infer actual discharge
Whether Zions is estopped from collecting because the 1099‑C and other acts misled Crapo	Crapo relied on the 1099‑C ("FORGIVEN DEBT") and paid taxes accordingly; that reliance makes estoppel appropriate	Any reliance was unreasonable because the 1099‑C itself is ambiguous and warns that an identifiable event may not mean actual discharge; Crapo did not investigate	Court: Estoppel fails — reasonable reliance element not met as a matter of law; Crapo had duty to investigate ambiguous 1099‑C and presented no evidence of doing so
Entitlement to appellate attorney fees	(Crapo) Not asserted	Zions seeks fees because it was awarded fees below and prevailed on appeal	Court: Zions entitled to fees on appeal; remand to district court to quantify reasonable appellate fees and costs

Federated Capital Corp. v. Libby, 384 P.3d 221 (Utah 2016) (summary judgment standard and appellate review described)
FDIC v. Cashion, 720 F.3d 169 (4th Cir. 2013) (holding a Form 1099‑C alone does not establish discharge)
AmTrust Bank v. Fossett, 224 P.3d 935 (Ariz. Ct. App. 2010) (view that issuance of a 1099‑C may be prima facie evidence of discharge)
IHC Health Servs., Inc. v. D & K Mgmt., Inc., 196 P.3d 588 (Utah 2008) (courts must draw reasonable, not speculative, inferences at summary judgment)
Youngblood v. Auto‑Owners Ins. Co., 158 P.3d 1088 (Utah 2007) (elements of equitable estoppel)
Dillon v. S. Mgmt. Corp. Ret. Trust, 326 P.3d 656 (Utah 2014) (prevailing party entitled to appellate fees when fees were awarded below)