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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.8
To reflect the foregoing,
An appropriate order will be
issued denying the motion to
dismiss for lack of jurisdiction
as to Karin M. Locke and granting
the motion to dismiss for lack of
jurisdiction as to Edwin A.
Locke, Jr.
8
Also without merit is Mrs. Locke's argument that a
failure to allocate 100 percent of the partnership interests to
Mr. Locke could potentially result in double taxation.
Respondent is entitled to have any tax liability arising from Mr.
Locke's investments in the partnerships 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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