T.C. Memo. 2004-147
UNITED STATES TAX COURT
JOSE GRACIA AND NANCY GRACIA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6642-02. Filed June 22, 2004.
Robert B. Scarlett, for petitioners.
Bradley C. Plovan, for respondent.
MEMORANDUM OPINION
THORNTON, Judge: Petitioner husband (petitioner) was a
general partner in a partnership. Petitioner personally
guaranteed certain of the partnership’s debts. After the
partnership filed for bankruptcy under chapter 11, the bankruptcy
court discharged petitioner’s personal liability with respect to
the partnership’s debts and petitioner’s personal guaranty
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