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limitations set forth in section 6501(a) by providing that the
assessment procedure may be expedited where a request for prompt
assessment is filed on behalf of a decedent, the decedent's
estate, or a corporation. Section 6501(d) does not provide
prompt assessment relief to a surviving spouse. See Garfinkel v.
Commissioner, 67 T.C. 1028, 1032-1033 (1977); Estate of Severt v.
Commissioner, T.C. Memo. 1998-34. Similarly, we conclude that
section 301.6231(c)-8T, Temporary Proced. & Admin. Regs., 52 Fed.
Reg. 6794 (Mar. 5, 1987), which provides that partnership items
will be treated as nonpartnership items "with respect to a
partner on whose behalf a request for a prompt assessment of tax
under section 6501(d) is filed", does not apply to the surviving
spouse of a deceased partner.
We note that in Dubin v. Commissioner, 99 T.C. 325, 334
(1992), we rejected a similar argument under analogous
circumstances. In Dubin v. Commissioner, supra, the taxpayer and
her husband held a joint interest in a partnership. Because the
taxpayer's husband was named as a debtor in a bankruptcy
proceeding, his partnership items converted to nonpartnership
items pursuant to section 301.6231(c)-7T(a), Temporary Proced. &
Admin. Regs., 52 Fed. Reg. 6793 (Mar. 5, 1987). However, in a
reversal of the positions of the parties in the instant case, the
Commissioner argued in Dubin that the partnership items of the
taxpayer (wife) had converted to nonpartnership items at the time
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