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limited partnership when he or she files a voluntary petition in
bankruptcy. See Tex. Rev. Civ. Stat. Ann. art. 6132a-1, sec.
4.02(a)(4)(B) (West 1999). Thus, petitioners contend that
petitioner ceased being the general partner of GSD, and GSD
dissolved, when petitioner filed the petition in bankruptcy on
July 11, 1991. We disagree. The GSD provision which states that
GSD terminated upon the bankruptcy of its general partner did not
cause GSD to terminate on July 11, 1991, because Federal law, not
State law, controls when a partnership terminates for Federal tax
purposes. See Fuchs v. Commissioner, 80 T.C. 506, 510 (1983)
(State law dissolution does not cause a partnership to terminate
for Federal tax purposes); Estate of Skaggs v. Commissioner, 75
T.C. 191, 198 (1980), affd. 672 F.2d 756 (9th Cir. 1982).
Petitioners would not prevail even if State law controlled
when a partnership terminated for tax purposes. Under Texas law,
a partnership is not terminated on dissolution but continues
until the winding up of partnership affairs is completed. See
Tex. Rev. Civ. Stat. Ann. art. 6132b, sec. 30 (West 1999); Kelly
Associates v. Aetna Casualty and Sur Co., 681 S.W.2d 593, 596-597
(Tex. 1984). Petitioners contend that the winding up of GSD’s
affairs was complete on July 11, 1991. Under Texas law,
litigation of claims by and against partners is part of the
winding up of a partnership. See United States v. Saks, 964 F.2d
1514, 1524-1525 (5th Cir. 1992). See generally Crane & Bromberg,
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