Treasury Regulations (26 C.F.R.)

26 CFR § 301.6231(c)-5

Criminal investigations.

Official textecfr.govlast amended

# (a) In general.

The treatment of items as partnership items with respect to a partner under criminal investigation for violation of the internal revenue laws relating to income tax will interfere with the effective and efficient enforcement of the internal revenue laws. Accordingly, partnership items of such a partner arising in any partnership taxable year ending on or before the last day of the latest taxable year of the partner to which the criminal investigation relates shall be treated as nonpartnership items as of the date on which the partner is notified that the partner is the subject of a criminal investigation and written notification is sent by the Internal Revenue Service that the partner's partnership items shall be treated as nonpartnership items. The partnership items of a partner who is notified that the partner is the subject of a criminal investigation shall not be treated as nonpartnership items under this section unless and until such partner is sent written notification from the Internal Revenue Service of such treatment.

# (b) Effective date.

This section is applicable to partnership taxable years beginning on or after October 4, 2001. For years beginning prior to October 4, 2001, see § 301.6231(c)-5T contained in 26 CFR part 1, revised April 1, 2001.

[T.D. 8965, 66 FR 50561, Oct. 4, 2001]

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In this part (40 sections)
  1. 301.6229(b)-2 · Special rule with respect to debtors in title 11 cases.
  2. 301.6229(c)(2)-1 · Substantial omission of income.
  3. 301.6229(e)-1 · Information with respect to unidentified partner.
  4. 301.6229(f)-1 · Special rule for partial settlement agreements.
  5. 301.6230(b)-1 · Request that correction not be made.
  6. 301.6230(c)-1 · Claim arising out of erroneous computation, etc.
  7. 301.6230(e)-1 · Tax matters partner required to furnish names.
  8. 301.6231-1 · Notice of proceedings and adjustments.
  9. 301.6231(a)(1)-1 · Exception for small partnerships.
  10. 301.6231(a)(2)-1 · Persons whose tax liability is determined indirectly…
  11. 301.6231(a)(3)-1 · Partnership items.
  12. 301.6231(a)(5)-1 · Definition of affected item.
  13. 301.6231(a)(6)-1 · Computational adjustments.
  14. 301.6231(a)(7)-1 · Designation or selection of tax matters partner.
  15. 301.6231(a)(7)-2 · Designation or selection of tax matters partner for…
  16. 301.6231(a)(12)-1 · Special rules relating to spouses.
  17. 301.6231(c)-1 · Special rules for certain applications for tentative…
  18. 301.6231(c)-2 · Special rules for certain refund claims based on…
  19. 301.6231(c)-3 · Limitation on applicability of §§ 301.6231(c)-4 through…
  20. 301.6231(c)-4 · Termination and jeopardy assessment.
  21. 301.6231(c)-5 · Criminal investigations.
  22. 301.6231(c)-6 · Indirect method of proof of income.
  23. 301.6231(c)-7 · Bankruptcy and receivership.
  24. 301.6231(c)-8 · Prompt assessment.
  25. 301.6231(d)-1 · Time for determining profits interest of partners for…
  26. 301.6231(e)-1 · Effect of a determination with respect to a…
  27. 301.6231(e)-2 · Judicial decision not a bar to certain adjustments.
  28. 301.6231(f)-1 · Disallowance of losses and credits in certain cases.
  29. 301.6232-1 · Assessment, collection, and payment of imputed…
  30. 301.6233-1 · Extension to entities filing partnership returns.
  31. 301.6233(a)-1 · Interest and penalties determined from reviewed year.
  32. 301.6233(b)-1 · Interest and penalties with respect to the adjustment…
  33. 301.6234-1 · Judicial review of partnership adjustment.
  34. 301.6235-1 · Period of limitations on making adjustments.
  35. 301.6241-1 · Definitions.
  36. 301.6241-2 · Bankruptcy of the partnership.
  37. 301.6241-3 · Treatment where a partnership ceases to exist.
  38. 301.6241-4 · Payments nondeductible.
  39. 301.6241-5 · Extension to entities filing partnership returns.
  40. 301.6241-6 · Coordination with other chapters of the Internal Revenue…
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