Salvador A. and Kathleen M. Gaudiano - Page 16

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               We conclude that the first guaranty was supported by                   
          adequate and sufficient consideration and was enforceable.                  
          Therefore, Appolo is not entitled to a bad debt deduction for the           
          Four A debt, and, accordingly, G. Asher and L. Asher are not                
          entitled to ordinary losses related to the bad debt deduction.              
               To reflect the foregoing,                                              
                                                  Decisions will be entered           
                                             under Rule 155.                          


                                                                                     




























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