First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 15

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               We have considered all the other arguments made by the                 
          parties and, to the extent not discussed above, find them to be             
          irrelevant or without merit.10                                              
               To reflect the foregoing,                                              
                                             An appropriate order will be             
                                        issued denying the motion to                  
                                        dismiss for lack of jurisdiction              
                                        as to JoAnn Scarfia, and granting             
                                        the motion to dismiss for lack of             
                                        jurisdiction as to Michael J.                 
                                        Scarfia.                                      














               10                                                                     
                    Also without merit is Mrs. Scarfia's argument that a              
          failure to allocate 100 percent of the partnership interest to              
          Mr. Scarfia could potentially result in double taxation.                    
          Respondent is entitled to have any tax liability arising from Mr.           
          Scarfia's investment in the partnership satisfied only once.  See           
          Dolan v. Commissioner, 44 T.C. 420, 430 (1965).  Full payment of            
          a joint and several obligation by one obligor extinguishes the              
          liability of all obligors.  Kroh v. Commissioner, 98 T.C. 383,              
          397 (1992); Dolan v. Commissioner, supra at 430.                            




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