Assessment of Partnership Items, Converted to Nonpartnership Items

ID: CCA_2009062408565137 Number: 200929016
Release Date: 7/17/2009
Office: ---
UILC: 6229.07-00
From: ---
Sent: Wednesday, June 24, 2009 8:56:54 AM
To: ---
Cc: ---
Subject: RE: 1 year assessment by 6-30-2009
You are correct that If your partner is a taxable individual or C corp and did not file a return, you can assess at any time. You are not constrained by the one year minimum period that might otherwise apply.
I don't know why you think the dissolution of the partnership would negate taxable income from that entity.
Dissolution, by itself, is not a loss event.