- 10 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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