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within the personal jurisdiction of this Court under section
6226(c).
Significantly, Mrs. Locke 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.
Locke'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, 1987); (emphasis added). Mrs.
Locke does not contend that she ever was in bankruptcy, and thus
she is not within literal application of this rule.
Instead, Mrs. Locke 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. Locke argues that the quoted language should
be interpreted to mean "the partnership items related to such
partner".
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