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We disagree with Mrs. Locke's construction of the statute.
The language in section 6226(d)(1)(A) parallels that of the
bankruptcy rule. Both are specific in targeting only the debtor
and in converting only the partnership items of the debtor.
Moreover, Mrs. Locke's expansive reading of section 6226(d)(1)(A)
is contrary to the fundamental principle of statutory
construction that where a statute is clear on its face,
unequivocal evidence of legislative purpose is required to
override the plain meaning of the words used. Huntsberry v.
Commissioner, 83 T.C. 742, 747-748 (1984). As Mrs. Locke has
proffered no such evidence, we decline to adopt the broad
interpretation urged upon us.
Respondent argues that the resolution of this issue is
controlled by this Court's decision in Dubin v. Commissioner, 99
T.C. 325 (1992). In Dubin this Court addressed the impact of the
bankruptcy rule upon a taxpayer who held a joint interest in a
partnership with her husband and with whom she had filed a joint
return. The taxpayer's husband was named as a debtor in a
bankruptcy proceeding prior to the issuance of a single notice of
deficiency that disallowed certain partnership losses and
credits. The taxpayer filed a motion to dismiss for lack of
jurisdiction on the ground that respondent's notice of deficiency
was invalid for failure to comply with the TEFRA procedures. We
noted that section 6231(a)(12) provides a general rule, subject
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