Chester L. Price - Page 1

                                 T.C. Memo. 2004-149                                  

                               UNITED STATES TAX COURT                                

                           CHESTER L. PRICE, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6639-02.             Filed June 22, 2004.                   

               William M. Davidow, Jr., for petitioner.                               
               Bradley C. Plovan, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               THORNTON, Judge:  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 thereof.  The issue for decision             

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