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account directly or indirectly partnership items of the
partnership.
Section 301.6231(a)(2)-1T(a)(1), Temporary Proced. & Admin.
Regs., 52 Fed. Reg. 6790 (Mar. 5, 1987), provides that a spouse
who files a joint return with an individual holding a separate
interest in the partnership shall be treated as a partner for
purposes of the TEFRA provisions and is permitted to participate
in administrative and judicial proceedings.
Section 6226(c)(1) provides that if a partnership action is
brought under section 6226(a) or (b) each person who was a
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
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