First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 8

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          distinction between married women and married men in the holding,           
          control, disposition, or encumbering of their property, both real           
          and personal".  Fla. Const. art. X, sec. 5; see Hallman v.                  
          Hospital & Welfare Bd., 262 So.2d 669, 670 (Fla. 1972).  Florida            
          law permits husbands and wives to hold, control, encumber, or               
          dispose of separate property without joinder or consent of their            
          spouses in all respects as if they were unmarried.  Fla. Stat.              
          Ann. sec. 708.08 (West 1988); Holland v. Holland, 406 So.2d 496,            
          497-498 (Fla. Dist. Ct. App. 1981).                                         
               In the instant cases, the parties have stipulated that Mr.             
          Scarfia purchased the partnership interest in his name, and that            
          the partnership issued all Schedules K-1 solely in Mr. Scarfia's            
          name.  We conclude that Mrs. Scarfia had neither a joint interest           
          in Mr. Scarfia's partnership investment nor a separate interest             
          in the partnership.                                                         
          Analysis Under TEFRA                                                        
               The parties agree that as of the date that Mr. Scarfia filed           
          a voluntary petition in bankruptcy, all partnership items                   
          attributable to him were converted to nonpartnership items by               
          conjunctive operation of the bankruptcy rule and section 6231(b)            
          and (c).  As a result of that conversion, this Court in a                   
          partnership proceeding does not have jurisdiction with respect to           
          Mr. Scarfia pursuant to section 6226(d)(1)(A) and (f).                      







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