Kenneth B. and Linda R. Satlin - Page 15

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          dealings between the parties; and lack of assets.  Am. Offshore,            
          Inc. v. Commissioner, supra at 594-595.  No single factor is                
          conclusive.  Id. at 595.                                                    
               Respondent argues that petitioners did not show that the               
          notes evidencing the debt owed them became worthless.  Respondent           
          further argues that petitioners’ respective security interests in           
          the 3513 property and the 3532 property survived the bankruptcy             
          and that petitioners failed to institute foreclosure proceedings.           
               A debtor’s petition in bankruptcy is not conclusive of a               
          debt’s total worthlessness.  Estate of Mann v. United States, 731           
          F.2d 267, 276 (5th Cir. 1984); Dallmeyer v. Commissioner, 14 T.C.           
          1282, 1292-1293 (1950).  Ordinarily, liens and other secured                
          interests survive bankruptcy.  Farrey v. Sanderfoot, 500 U.S.               
          291, 297 (1991).  A lien on real property passes through                    
          bankruptcy unaffected.  Dewsnup v. Timm, 502 U.S. 410, 418                  
          (1992).  A bankruptcy discharge extinguishes only one mode of               
          enforcing a claim--namely, an action against the debtor in                  
          personam--while leaving intact another--namely, an action against           
          the debtor in rem.  Johnson v. Home State Bank, 501 U.S. 78, 84             
          (1991).                                                                     
               Petitioners established that a debtor-creditor relationship            
          existed, as evidenced, in part, by two settlement statements                
          dated July 7, 1983, which detailed the sale of the 3513 property            
          and the 3532 property to the debtors.  The record establishes               






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