- 6 - The partnership’s chapter 11 bankruptcy was a case under title 11 of the United States Code. See 11 U.S.C. ch. 11 (2000). Pursuant to its December 19, 1995, order, the bankruptcy court discharged and released petitioner from all liability to the trustee, the bank, and all other creditors that might have claims arising from or relating to the partnership, petitioner’s status as a general partner in the partnership, and the April 9, 1985, personal guaranty agreement. In the same order, the bankruptcy court explicitly asserted its jurisdiction over petitioner for 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 petitioner.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011