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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