Exception for Small Partnerships

ID:
Office:
UILC:
CCA_2009040712315137
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6231.01-01
Number: 200920049
Release Date: 5/15/2009
From: ---
Sent: Tuesday, April 07, 2009 12:31:53 PM
To: ---
Cc: ---
Subject: RE: TEFRA election
Section 708(a) deems a partnership terminated "for purposes of this subchapter". "This subchapter" is subchapter K which governs the accounting of partnership items. Thus, while a termination might affect an accounting election under section 703(b) (--- would have to opine on this), a technical termination might not affect an election made under another subchapter such as the TEFRA subchapter C of Chapter
63. So the election not to be treated as a small partnership under section 6231(a)(1) may still be effective, notwithstanding the technical termination.
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