Richard K. and Marilyn J. Phillips - Page 19




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          regulations promulgated to address other special enforcement                
          areas.  For example, the Secretary did not explicitly require               
          that a taxpayer receive written notification in every special               
          enforcement situation.  Rather, each special enforcement                    
          regulation begins with language similar to the language of                  
          section 6231(c)(2):                                                         
               The treatment of items as partnership items with                       
               respect to a partner * * * [in a specifically described                
               circumstance] will interfere with the effective and                    
               efficient enforcement of the internal revenue laws.                    
          Sec. 301.6231(c)-6T, Temporary Proced. & Admin. Regs., 52 Fed.              
          Reg. 6793 (Mar. 5, 1987) (providing that the partnership items of           
          a partner whose taxable income is determined by use of an                   
          indirect method of proof shall be treated as nonpartnership items           
          on the date of the mailing of the deficiency notice); see also              
          sec. 301.6231(c)-7T, Temporary Proced. & Admin. Regs., 52 Fed.              
          Reg. 6793 (Mar. 5, 1987) (providing that the partnership items of           
          a partner named as debtor in a bankruptcy proceeding become                 
          nonpartnership items as of the filing of the bankruptcy                     
          petition).                                                                  
               After this introductory language, each special enforcement             
          regulation specifically sets forth what circumstances will                  
          interfere with the effective and efficient enforcement of the               
          internal revenue laws and when partnership items in that                    
          situation will be treated as nonpartnership items.                          








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