I'm not sure of the exact mechanism, but... no. This was a common money laundering tactic in the '80s and '90s. At some point the IRS can declare the debt forgiven regardless of whatever the debt holder says, in the same way they can declare your money-losing business a "hobby" if they think you're not actually trying to make money.

The IRS has pretty wide latitude in these kinds of cases - I think the tax code is the only area of law where the government pretty much wins unless you prove your innocence.