First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 6

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          partner in such partnership at any time during the year in issue            
          shall be treated as a party to such action.  However, section               
          6226(d)(1)(A) provides, in pertinent part, that section 6226(c)             
          shall not apply to a partner after the day on which the                     
          partnership items of such partner for the particular partnership            
          taxable year become nonpartnership items by reason of one of the            
          events described in section 6231(b).  Section 6231(b)(1)(D)                 
          provides, in part, that for purposes of the TEFRA provisions the            
          partnership items of a partner shall become nonpartnership items            
          as of the date a change occurs under subsection (c) of section              
          6231.                                                                       
               Section 6231(c) provides that in certain special enforcement           
          areas the Secretary may provide by regulations for the conversion           
          of a partner's partnership items into nonpartnership items.                 
          Computer Programs Lambda, Ltd. v. Commissioner, 89 T.C. 198, 203            
          (1987); see H. Conf. Rept. 97-760, at 610 (1982), 1982-2 C.B.               
          600, 667.  Pursuant to this grant of authority, the Secretary               
          promulgated the so-called bankruptcy rule which provides as                 
          follows:                                                                    
                    (a)  Bankruptcy.  The treatment of items as partnership           
               items with respect to a partner named as a debtor in a                 
               bankruptcy proceeding will interfere with the effective and            
               efficient enforcement of the internal revenue laws.                    
               Accordingly, partnership items of such a partner arising in            
               any partnership taxable year ending on or before the last              
               day of the latest taxable year of the partner with respect             
               to which the United States could file a claim for income tax           
               due in the bankruptcy proceeding shall be treated as                   
               nonpartnership items as of the date the petition naming the            




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