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