Items Cease to Be Partnership Items in Certain Cases

ID: CCA_2011121914075137 Number: 201202025
Release Date: 1/13/2012
Office: ---
UILC: 6231.13-00
From: ---
Sent: Monday, December 19, 2011 2:07:59 PM
To: ---
Cc: ---
Subject: RE: TEFRA exams with bankrupt partner
Yes. For a bankrupt partner whose partnership items have converted to nonpartnership items under
Treas. Reg. 301.6231(c)-7, we must issue a converted item notice of deficiency under section
6230(a)(2)(A)(ii) within the later of the partner's section 6501 period for assessment or one year from the date of conversion under section 6229(f).