Greenberg Brothers Partnership #12, a.k.a. Lone Wolf McQuade Associates, and Richard M. Greenberg, Tax Matters Partner - Page 5

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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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