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this purpose. Giving due regard to principles of judicial
comity, we discern no reason to second-guess the bankruptcy
court’s assertion of jurisdiction over petitioner in the
partnership’s chapter 11 bankruptcy case. See 28 U.S.C. secs.
151, 157, 1334 (2000).
We conclude that petitioner’s debts in question were
discharged “in a title 11 case” within the meaning of section
108(d)(2). Accordingly, we hold that petitioner’s discharge of
indebtedness income is excludable from gross income pursuant to
section 108(a)(1)(A).
We have considered all arguments raised by the parties.
Arguments not addressed herein are moot, irrelevant, or without
merit.
To reflect the foregoing,
Decision will be entered
for petitioners.
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Last modified: May 25, 2011