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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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