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Price v. Commissioner

Docket No. 6639-02.

87 T.C.M. 1426 (2004)

T.C. Memo. 2004-149

Chester L. Price v. Commissioner.

United States Tax Court.

June 22, 2004.

Attorney(s) appearing for the Case

William M. Davidow, Jr., for petitioner.

Bradley C. Plovan, for respondent.

MEMORANDUM OPINION

THORNTON, Judge:

Petitioner was a general partner in a partnership. Petitioner personally guaranteed certain of the partnership's debts. After the partnership filed for bankruptcy under chapter 11, the bankruptcy court discharged petitioner's personal liability with respect to the partnership's debts and petitioner's personal guaranty thereof. The issue for decision is whether the resulting discharge of indebtedness income is excludable...

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