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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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