BARKETT, Circuit Judge:
Appellant Stephen P. Wolfson ("Wolfson") appeals from a district court judgment affirming a bankruptcy court's decision excepting $1,815,805 of Wolfson's debt from discharge. Because we conclude that the debt was excepted in error, we reverse.
From 1971 to 1990, Wolfson and his brother, Gary, were partners in a horse farm known as the Happy Valley Farm (the "Farm"). In 1987, Equine Capital Corporation ("ECC") replaced Citibank, N.A...
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