First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 10

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               Significantly, Mrs. Scarfia is unable to point to any                  
          statute or regulation explicitly divesting this Court of                    
          jurisdiction over her as a necessary concomitant to the                     
          conversion of Mr. Scarfia's partnership items under the                     
          bankruptcy rule.  The bankruptcy rule provides that the                     
          "partnership items of such a partner * * * shall be treated as              
          nonpartnership items as of the date the petition naming the                 
          partner as debtor is filed in bankruptcy".  Sec. 301.6231(c)-               
          7T(a), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6793 (Mar.            
          5, 1989); (Emphasis added.).  Mrs. Scarfia does not contend that            
          she ever was in bankruptcy, and thus she is not within the                  
          literal application of this rule.                                           
               Instead, Mrs. Scarfia makes an interpretative argument based           
          upon section 6226(d)(1)(A).  That section provides that this                
          Court loses personal jurisdiction over a partner after the day on           
          which "the partnership items of such partner * * * became                   
          nonpartnership items" by reason of certain events, including the            
          naming of the partner as a debtor in bankruptcy.  (Emphasis                 
          added.)  To bring herself within the ambit of section                       
          6226(d)(1)(A), Mrs. Scarfia argues that the quoted language                 
          should be interpreted to mean "the partnership items related to             
          such partner".                                                              
               We disagree with Mrs. Scarfia's construction of the statute.           
          The language in section 6226(d)(1)(A) parallels that of the                 





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